Bookkeeping is a regulated profession following the revisions to the Money Laundering Regulations (MLR) in 2007 and again in 2017. If you are providing a bookkeeping service to clients or are seen as carrying out bookkeeping 'by way of business' you must:
- be monitored by an HM Treasury appointed supervisory authority, such as ICB
- put in place certain controls to identify, prevent and report money laundering offences – known as anti-money laundering or AML
For more information on the meaning of 'by way of business' please visit HMRC Manual MLR2R1300
Fitness and Propriety
As per Regulation 26 of the Money Laundering Regulations 2017, external Bookkeepers and Beneficial Owners, Managers and Officers of a Bookkeeping Practice must not have any unspent Schedule 3 criminal convictions relating to fraud and dishonesty.
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Anti-Money Laundering Supervision (AML)
Members with an ICB Practice Licence are automatically supervised under the MLR. As an ICB Practice Licence holder, compliance with the MLR is dependent on you:
- Establishing and regularly maintaining AML policies and procedures specific to your practice
- Completing a practice-wide Risk Assessment of the money laundering risks faced by the practice
- Completing a Risk Assessment for each of your clients via AML Online
- Carrying out appropriate due diligence on each of your clients, and recording this on AML Online
- Reviewing each client's due diligence & risk assessment, and your own AML procedures and practice risk assessment, at least annually
- Renewing your Practice Licence on time each year and keeping your ICB membership up to date
- Ensuring your ICB registered details are correct at all times
- Abiding by the ICB Professional Conduct Regulations, in particular those on AML compliance, and ensuring you comply with the requirements contained within the AML Guidance page of the ICB website.
> Log in to AML online to update your online anti-money laundering records
> Log in to MyICB to update your details, add BOOM information, DBS Basic Checks, and check your membership status
> Apply for a Practice Licence
Detailed AML Guidance for ICB supervised practices:
> AML Guidance
Confidential AML Whistleblowing hotline:
0203 405 7581
Supervision by another body
You need only have one AML supervisor. If you are a member of another HM Treasury appointed supervisor, such as ICAEW or ACCA, please forward a copy of supporting documents to firstname.lastname@example.org
As an ICB member in practice you are still required to hold a Practice Licence even if you have an alternative AML supervisor.
Supervision of non-members
ICB is pleased to extend its anti-money laundering supervision scheme to practising members of the following bodies:
Please contact us if you would like further information.
0203 405 4000
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