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AML and subcontractors

  • Fellow
  • Practice Licence
  • 71 posts
  • # 119113

Morning All

If I take on sub-contractors do they have to have AML cover of their own or would they fall under "staff training"?


  • Companion Fellow PM.Dip
  • Practice Licence
  • 33 posts
  • # 119114

Hi there,

ICB requires you to work with subcontractors who have AML supervision and are sufficiently qualified. Please update your staff, BOOMS and subcontractors list on MyICB. There will shortly be a subcontractor agreement template available for you to download and, in the meantime, I've provided a bit more information below and recommend you please call our practice onboarding manager, Sujay Patel, on 0203 405 4000 if there's anything you'd like to discuss.

You can outsource/subcontract to someone else to undertake work that you're not qualified to do, or work that you don't want/have time to carry out yourself. However, their work is your responsibility and you should:

-ensure the subcontractor is sufficiently qualified and put in place controls to monitor their work

-request evidence from the subcontractor of their AML supervision and Professional Indemnity Insurance

-check with your insurance supplier that you are covered

-have a written agreement with the subcontractor that requires them, as a data processor, to comply with all data protection laws. The agreement must also clearly define the level of work to be carried out, the boundaries and payment terms

-be upfront with your clients, though of course this can be a selling point

-update your Privacy Policy to include the fact that you're sharing your clients' data with a data processor and then notify your clients that you've updated the policy. There is a template privacy policy for members to use here:

-add details of your subcontractors (and also any employees or BOOMs) to your account by visiting MyICB online within 14 days of any changes. You can also notify us of any changes by email.

We would recommend you take advantage of ICB's online Practice Directory search or free job vacancy facility on our website here:

When you engage an ICB member you can check their credentials with us and be confident they are governed by the same regulations and ethical code as yourself.

Good luck finding the right person!


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