AMLA Starts Operations

AMLA Starts Operations

In case you haven’t already heard designated persons (that includes accountants in practice) have a new regulator called the ‘Authority for Anti-Money Laundering and Countering the Financing of Terrorism’. Originally created in June 2024, the Board held its first meeting in March 2025 and the chair is Bruna Szego.

The aim of this new authority is to coordinate national AML authorities around Europe to ensure the correct and consistent application of AML rules in each jurisdiction.

AMLA will also supervise supervisory bodies in Europe including the Institute and enhance cooperation among police financial intelligence units (FIUs).

Ms Szego will be at the RDS in Dublin in May to give the Keynote Address at the European Anti-Financial Crime Summit 2025.

It’s expected that AMLA will be fully operational by 1 January 2028 with a staff complement of 430.

For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.

For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:

ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements.  Please contact John McCarthy FCA by email at john@jmcc.ie.

Do you Need to be an ACSP?

Do you Need to be an ACSP?

If you have corporate clients in the UK, you may wish to register with Companies House as an Authorised Corporate Service Provider (ACSP).  This is a new requirement driven by the rise in money laundering and fraud using corporate structures. ACSPs are also known as Companies House Authorised Agents.

The ACSP initiative is being rolled out in stages. Stage 1 commenced on 8 April 2025, when the service allowed authorised agents, such as accountants, to verify clients’ identities for Companies House purposes. Records of the identity checks need to be retained by the agents for 7 years.

File as an Authorised Agent

The next stage will commence in Spring 2026, when authorised agents will be able to file on behalf of clients.

An authorised agent can be a business (for example, a limited company or partnership), or a person who files on behalf of others (a sole trader).

To register, agents must be supervised by a UK Anti-Money Laundering (AML) supervisory body such as Chartered Accountants Ireland. In the future, all businesses that file information on behalf of clients will need to register as an ACSP.

For more information and to start the registration process follow this link.

For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.

For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:

ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements.  Please contact John McCarthy FCA by email at john@jmcc.ie.

Fraudulent Payments

Fraudulent Payments

The Central Bank published some new data in a report about fraudulent payments in January this year which did not get the full attention it deserves.  The data on payment fraud reveals that Irish fraud rates are below the EU averages except for card payments. Most fraudulent payments are sent to fraudsters’ accounts located outside Ireland with fraudulent credit transfers being the most popular method.

Fraudsters continually adopt new ways to exploit digital systems and bypass security measures, costing businesses and individuals millions of euros every year. Common methods include phishing, where fake emails or text messages trick people into revealing personal information, psychological manipulation of the payer to send money via social networks or impersonating as a trusted party, making unauthorised payments using lost or stolen cards.

The report shows that fraudulent payments on the rise but fraud rates remains low. The rate of fraud in Ireland as a share of all transactions is low. By value, the rate is 0.001%, and by volume, the rate is 0.01%, with the latter being equivalent to 1 in 10,000 payment transactions impacted by fraud.

The total value of fraudulent payments rose by 26% in 2023, increasing to €126 million from €100 million in 2022. Credit transfers and card payments accounted for the majority of all fraud.

As per the published data on payment statistics, credit transfers are the largest in terms of value and often used for large value payments compared with other payment methods in Ireland. This also applies to fraudulent payments.

Approximately 60% of the value of fraud, amounting to €70 million in 2023, was made through credit transfer.

For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.

For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:

ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements.  Please contact John McCarthy FCA by email at john@jmcc.ie.

The Three Most Important Items on an Audit File

The Three Most Important Items on an Audit File

It’s the best slogan invented by estate agents which they say are the three most important things with property which are location, location, location. 

The same could be said for the most common audit file weakness. The three most important things to have on audit file are Documentation, Documentation, Documentation. 

Documentation is key.

The audit standard on this topic is Audit Documentation ISA (Ireland) 230.

The most common audit file weaknesses often involve a lack of documentation evidencing the audit work that has been performed.

Too often it is unclear:

  • which audit assertion is being tested;
  • how an assertion has been tested;
  • what the full results of the test are; and/or
  • how outstanding points/queries have been cleared.

In many cases audit teams are able to provide additional verbal explanations or evidence but the fact that this is necessary is a good indication that the quality and extent of documentation needs improvement.

Every audit assertion being tested should be supported by a clear work paper record in the form of a schedule detailing:

  • the objective;
  • the method (including sample size and selection methods);
  • the results; and
  • the overall conclusion and sign off by the audit engagement partner.

Just a quick reminder that the 12 main audit assertions are in ISA (Ireland) 315.A190 and are divided into two main classes:

Income Statement or Profit & Loss Account

(i) Occurrence – the transactions and events that have been recorded or disclosed have actually occurred, and such transactions and events pertain to the entity.

(ii) Completeness – all transactions and events that should have been recorded have been recorded, and all related disclosures that should have been included in the financial statements have been included (probably the most difficult assertion to prove)

(iii) Accuracy – amounts and other data relating to recorded transactions and events have been recorded appropriately, and related disclosures have been appropriately measured and described.

(iv) Cut–off – transactions and events have been recorded in the correct accounting period.

(v) Classification – transactions and events have been recorded in the proper accounts (either P&L versus Balance Sheet).

(vi) Presentation – transactions and events are appropriately aggregated or disaggregated and clearly described, and related disclosures are relevant and understandable in the context of the requirements of the applicable financial reporting framework.

Balance Sheet and Related Disclosures at the Period End 

(i) Existence – assets, liabilities and equity interests actually exist.

(ii) Rights and obligations – the entity holds or controls the rights to assets, and liabilities are correctly the obligations of the entity.

(iii) Completeness – all assets, liabilities and equity interests that should have been recorded have been recorded, and all related disclosures that should have been included in the financial statements have actually been included.

(iv) Accuracy, valuation and allocation assets, liabilities and equity interests have been included in the financial statements measured at appropriate amounts and any resulting valuation or allocation adjustments have been appropriately recorded, and related disclosures have been appropriately measured and described.

(v) Classification – assets, liabilities and equity interests have been recorded in the correct accounts.

(vi) Presentationassets, liabilities and equity interests are appropriately aggregated or disaggregated and clearly described, and related disclosures are relevant and understandable in the context of the requirements of the applicable financial reporting framework.

For tailored training sessions explaining more about the ISAs, please send a mail to john@jmcc.ie.

For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:

ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements.  Please contact John McCarthy FCA by email at john@jmcc.ie.