Which legislation are we talking about?
The central regulations discussed here are the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, commonly called the MLR 2017. They are not the whole of UK financial crime law.
Sanctions obligations sit alongside AML requirements. A product that helps with identity and screening cannot be treated as a substitute for understanding which obligations apply to your business.
UK legislation: Money Laundering Regulations 2017Does the framework apply to your services?
Accountancy and bookkeeping businesses, tax advisers and trust or company service providers can fall within scope. Check your actual activities and supervisory arrangement, rather than relying only on your job title.
Professional-body supervision and HMRC supervision are not interchangeable registrations. Use the relevant sector guidance to establish which route applies.
HMRC: accountancy service provider supervisionWhat sits beyond an identity check?
Customer due diligence sits alongside business risk assessment, internal controls, staff responsibilities and ongoing monitoring. Firms also need appropriate records and processes for handling concerns.
This is why a single successful document check cannot establish that a firm has fulfilled all of its AML obligations. The checks need to sit inside a working process.
HMRC: your AML responsibilitiesWhere can AMLCode help?
AMLCode is designed around the client evidence journey: invitation, identity steps, screening, relevant company information and a connected report. This gives your firm a more organised starting point for reviewing a client case.
Your policy still needs to explain who can accept a client, when to request further information and how to manage the relationship after onboarding. Use current sector guidance and advice appropriate to your circumstances for those decisions.
Can software make a firm automatically AML compliant?
Software can support defined checks and record handling. Compliance also depends on the firm’s services, risk assessment, procedures, decisions and ongoing work.
This is a general introduction. Use current legislation and the guidance relevant to your services and supervisor when setting your firm’s procedures.