IFA Anti-Money Laundering Supervision
All firms conducting accountancy-related and trust or company services (TCSP) must be supervised by a supervisory body in accordance with Schedule 1 to the The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and the beneficial owners, officers and managers (BOOMs) of such firms must be approved by the supervisory body.
Who we supervise
A a sole practitioner, partnership, limited partnership or body corporate which is engaged in public practice where more than 50% of the rights to vote on all, or substantially all, matters of substance regarding the firm are held by members; and
A sole practice, partnership, limited liability partnership or a body corporate which is not a member firm but which has contracted with the IFA for supervision and oversight for anti-money laundering or other regulatory purposes and is subject to the Institute’s bye-laws and regulations.
Please note that:
- If a firm provides trust or company services (TSCP) as part of their main accountancy practice, all of their accountancy work (including TSCP) will be supervised by the IFA. Further information on what types of services are included in TCSP work and HMRC’s TSCP register can be found here.
- If a firm has a group structure and has subsidiaries which are authorised firms under the Financial Services and Markets Act for FCA-authorised activities, the IFA will supervise the non-FCA regulated work.
Our work is subject to oversight by the Office for Professional Body Anti-Money Laundering Supervision (OPBAS). In their report ‘Progress and themes’ from 2019, they concluded there had been strong improvement across both the legal and accountancy sectors in AML supervision.
Professional bodies also report annually to HM Treasury in order to improve the transparency and accountability of supervision and encourage good practice,
The IFA’s supervisory approach
Our approach to AML supervision ensures we can effectively monitor our firms and take measures when necessary to secure compliance with the Money Laundering Regulations 2017 and the Money Laundering Regulations 2019.
Key elements of our approach
We adopt a risk-based approach to supervision informed by the firm risk assessments we conduct. Our risk-based approach is based on information from the annual firm, member and affiliates returns as well as other sources.
The frequency and type of AML monitoring review is based on our firm risk assessments. We will conduct on-site monitoring visits or telephone (virtual) visits by trained, knowledgeable and approachable AML reviewers. If you are selected for a visit, we expect you to collaborate with the visit process.
At the end of the visit, we will advise you on any improvements you should make to reduce the risk to yourself and remain compliant with legislation. In addition, we will help you understand your obligations under the Money Laundering Regulations 2017 and the Money Laundering Regulations 2019 to ensure that you are fully compliant with the law.
We provide information to our supervised firms on the money laundering and terrorist financing practices that apply to the accountancy sector and a description of the circumstances in which we think there is a high risk of money laundering and terrorist financing.
We provide information, guidance and support to help our firms meet the requirements of the Money Laundering Regulations, including free Anti-Money Laundering Compliance software, AMLCC.
We encourage our supervised firms to report breaches of the Money Laundering Regulations, if need be, anonymously.
We will take disciplinary action against firms that don’t meet the requirements of the Money Laundering Regulations, including those that do not co-operate with the AML monitoring process.
What to expect during a monitoring visit
As part of the planning process, we will establish a single point of contact for our supervised firms for the exchange of anti-money laundering information and intelligence and for the monitoring visit.
The AML reviewer will request a list of documents to be reviewed either onsite or electronically if a remote or virtual visit is being conducted. If the firm uses AMLCC, the reviewer will request temporary access to AMLCC to review your documents. It is vital that the reviewer has access to relevant documents in order to conduct their work. The reviewer will also need to speak to all relevant individuals as part of their review.
What to expect after a visit
Following the visit, a report will be produced detailing whether or not you were compliant with the Money Laundering Regulations and, the steps that you are required to undertake to become compliant.
The report goes beyond compliance with the Money Laundering Regulations by also making suggestions for improving your practice management. You will be required to respond within 10 working days with an update on how you will action the required improvements.
Your commitments to the action plan will be assessed during a three-month period, offering further support if needed. Failure to implement the improvements identified in the action plan to the agreed deadlines or failure to co-operate with the monitoring and supervision process may lead to disciplinary action by the IFA.
Please contact the compliance department by email at email@example.com if you are have any queries regarding supervision or would like to apply to be supervised by the IFA.
In order to apply for AML supervision by legal contract (contracted firm), the firm must have at least one partner, owner or director who is an IFA member or the firm must be owned by a firm which has at least one IFA member.
Feedback on our supervisory visits
If you are worried about our supervisory visit or are wondering what the benefits are to your firm, please read some member endorsements.
"May I thank you personally for helping us through the AML procedures.
We’ve all learnt a lot.
Terry Hort FFA FTA, H&H Accountants Ltd
"We were delighted that we were picked for a AML supervision visit. The visit from start to finish was painless and efficient.
Alan Hind at the IFA was professional and very informative. He identified strengths and weaknesses at my practise and made constructive recommendations.
The IFA has an arrangement with AMLCC which is free for IFA members and I must say the system works great and saves a lot of time with compliances and AML in general."
Joseph Mills AFA, MIPA, ICPA, Managing Director, Alston Oak
"...when I first found out that were going to be looked into by the IFA anti-money laundering section I was quite concerned.
However, after having the meeting ...it was nothing like I expected. Alan Hind explained that he was here to assist us in reaching the correct standard required for the new AML rules.
I found the meeting to be very helpful and informative it also answered quite a lot of my concerns and made the situation regarding compliance a lot clearer.
I am very grateful to both Alan and the IFA for arranging the meeting. I personally think that what they are doing is brilliant."
D & D Accountancy Services Ltd
"We were selected for an AML review and we were quite apprehensive as we had never been through this before.
The review was to be carried out remotely because of lockdown measures and we had a list of information to send off in advance of the telephone appointment. We need not have worried, Andy Tennant was very helpful and informative and explained the whole process as we went along.
Luckily, everything went very well and for the one piece of missing information that we needed, Andy steered us in the right direction and it was sorted in a couple of days."
Cynthia Smith FFA FTA, C S Accounting Ltd