DON’T FORGET TO CARRY OUT AN ANNUAL MLR SYSTEMS REVIEW
ICB Director of Compliance, Ray Cross, reminds members to review their systems and files annually.
Dear All,
Can I remind all member practices that they should carry out an annual review of their anti-money laundering systems and procedures.
The review should ordinarily be carried out by the MLRO or somebody within the practice with the necessary authority and experience to conduct it. In most cases this will be the MLRO.
As long as the review is carried out annually, it does not necessarily matter at what time during the year you do it. Practices will need to decide when to carry it out, but obviously workloads will be a determining factor. I would recommend that the review is carried out at the same time that the Annual Client Declaration (MLR8) is completed and submitted to the Institute i.e. at time of renewal of your practice license.
It is important that written evidence is retained in respect of the work carried out during the review. There is a pre-printed review checklist in Section 3 of the ICB Manual and this should be completed, dated and signed off. Any documentation relating to the review should be retained, kept securely and only made available to duly authorised personnel within the practice.
During a review, you will probably come across weak points in your current procedures and any such weaknesses should be recorded, together with any actions required to put these right.
The person responsible for the overall review should record their conclusions to the results of the review.
When one of our compliance audit team visits your practice, he or she will want to establish that your practice has satisfactory anti-money laundering systems and procedures and that these procedures are being adhered to.
Our inspectors will also ask you whether you carry out an annual review of your systems and procedures. Undoubtedly the easiest and best way of satisfying the inspector is to show them a copy of your annual review compliance checklist and any supporting documentation.
Also please ensure that any weaknesses found during your review have been corrected.
As alluded to earlier, there is, in Section 3 sub-section 2 of the ICB Compliance Manual, a recommended checklist of questions which you should be asking yourself when you perform your annual review of anti-money laundering systems and procedures.
To remind everybody, money laundering regulations relevant to our work, include Part 7 of the Proceeds of Crime Act (POCA) 2002 and MLR 2007, which can be found on http://www.opsi.gov.uk
In addition, the ICB’s guidance from the Consultative Committee of Accountancy Bodies (CCAB) can be found in Section 2 of the ICB Compliance Manual.
Good luck.
Ray Cross
Director of Compliance