Registering for Supervision
Do I need to register?
All external accountants and tax advisers must be supervised for Anti Money Laundering (AML) purposes by a designated supervisory authority; the IFA is one of these.
The regulations also apply to interim managers, those providing company services (such as company formation services), external company secretaries and non executive directors, described as 'Trust and Company Service Providers' (TCSPs), and others working in specified industries (money service businesses, casinos, etc).
The IFA has already sent out an AML Registration Form to all members who hold Practising Certificates; these were due to be returned to IFA by the end of November 2009. If you are in practice but do not hold a current Practising Certificate, you are in contravention of the IFA Byelaws, and should contact Burford House immediately to rectify the position.
Who do I register with?
All members acting as external accountants, tax advisers or TCSPs are expected to register for supervision with the IFA, unless they are also members of another professional body listed in the regulations (Schedule 3 – see below for the full list)., in which case they must advise the IFA. Such bodies as the Association of Certified Practising Accountants and overseas bodies (except Chartered Accountants Ireland) have no jurisdiction in this respect.
If you are counted as a “money service business” because you have a consumer credit licence from the OFT, the Office of Fair Trading will be your supervisor, and not the IFA.
If you are a proprietor, partner or a director of a firm which has chosen to register with another supervisory authority you should advise the IFA at AML_Support@ifa.org.uk without delay, or preferably use Section E of the AML registration form and return it to IFA. Such a situation might arise because the majority of partners or directors belong to another professional body listed, or because the firm is supervised for audit or insolvency purposes by another body.
The accountancy and taxation professional bodies listed below have agreed that those required to register for supervision should do so with the body which has the higher level of qualification. It should not be necessary for IFA Members or Affiliates to register with more than one supervisory authority nor with the HMRC. HMRC charges £120 a year for supervision.
Schedule 3 - Regulations 17(2)(b),23(1)(c) and 32(4).
Professional bodies
Part 1:
1.Association of Chartered Certified Accountants
2. Council for Licensed Conveyancers
3. Faculty of Advocates
4. General Council of the Bar
5. General Council of the Bar of Northern Ireland
6. Institute of Chartered Accountants in England and Wales
7. Institute of Chartered Accountants in Ireland
8. Institute of Chartered Accountants of Scotland
9. Law Society
10. Law Society of Scotland
11. Law Society of Northern Ireland
Part 2:
12. Association of Accounting Technicians
13. Association of International Accountants
14. Association of Taxation Technicians
15. Chartered Institute of Management Accountants
16. Chartered Institute of Public Finance and Accountancy
17. Chartered Institute of Taxation
18. Faculty Office of the Archbishop of Canterbury
19. Insolvency Practitioners Association
20. Institute of Certified Bookkeepers
21. Institute of Financial Accountants
