Some suggestions for your annual AML checklist
Ever formed a list of your favourite things? Possibly not unless you live your life as an extra in The Sound of Music.
Favourite chocolate? Freddos (obvs). Can’t be any calories in them (too small) and its chocolate in the shape of a frog – what’s not to like?
Fave colour? OK, who really cares?
But what about your top ten fave AML questions on the annual due diligence form? Bet you’d never even thought of it had you? Of course not, you have a life to lead and AML is not even in the top 100 important things.
Problem is the regulatory bodies seem to think we are no longer accountants but AML-form-filling-in practices. It is truly bizarre a significant part of an ICAEW regulatory visit looks at AML but absolutely none i.e. zero that is zilch at the quality of your work.
Anyway, you have to complete an annual AML Due Diligence form on every client every year. See the article headed up about Lulu. Link to AML article
Questions for your AML Due diligence checklist
The problem is there is a lack of free checklists unless you have purchased a manual. So, in no particular order here are some questions you might include on your form:
1. Has there been any change to the ownership of the business?
2. Are there any new beneficial owners?
3. Is the client a PEP or become a PEP?
4. Are there any unsubstantiated transactions?
5. Does the client have cash transactions? Are there controls over them to help reassure us there are no undeclared sales?
6. Has there been any change in the nature of the trade?
7. Are there any new directors or partners?
8. Are there any new sources of funds for the business? Have we substantiated them?
9. Have we changed services or been asked to provide new services to this client?
10. Have they traded or started to trade with any countries on the Financial Action Task Force ‘banned’ lists?
11. Is the client under any financial pressure? (And, therefore, might be tempted to bend rules they wouldn’t usually).
12. Has the client any problems with a regulatory body?
13. Do we have any concerns that the client is run by a domineering personality type that could put us or others under pressure to act in ways that are not commensurate with our policies or the law?
(Note - we said 10 but there are 3 extra free ones).
As with any favourite lists (seriously, though if you have a fave AML list you really need a word with yourself) they change through time and will vary from practice-to-practice. There are some questions on this list that will never be relevant to you. Also, there could be some not on this list you might need to add. But it does give you an excellent start. (Yes, we have just said our list is excellent. Seems modesty is one of our favourite attributes!)