by John McCarthy Consulting Ltd. | Oct 27, 2025 | Blog, News
The UK Government has last week decided to pursue an AML supervision model of having a Single Professional Services Supervisor (SPSS). The date from which the change will be implemented has not yet been announced.
It intends to appoint the Financial Conduct Authority (FCA) to carry out the new supervisory functions as part of its remit and will be tasked with working with the professional services sector, other regulators, and law enforcement agencies to improve the UK’s defences against money laundering.
How the FCA will carry out these functions is yet to be worked out. They currently regulate 17,000 entities and this new responsibility will add another 60,000 entities (according to estimates by the Financial Times – link may require a subscription) to their stable of supervised entities.
The supervised firms which will switch regulator to the FCA include Legal Service Providers (LSPs), Accountancy Service Providers (ASPs), and Trust and Company Service Providers (TCSPs). This means that all firms currently supervised for AML/CTF matters by a PBS, and all ASPs and TCSPs supervised by HMRC (including High Value Goods Dealers) will be supervised by the FCA.
This change will obviously impact accountancy firms in Northern Ireland, but will the Irish Government decide to do something similar in the Republic of Ireland? There are already (as in the UK at present) multiple AML regulators of professional service firms along with the Department of Justice and the Central Bank, among others. Watch this space for future developments.
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.
by John McCarthy Consulting Ltd. | Oct 15, 2025 | Blog, News
Do you have a client business that deals or sells in boats or yachts where they may handle cash as part of the transaction?
Did you know that where the cash element of the transactions exceeds €10,000 in one single transaction or in a series of linked transactions, that your client is deemed to be a high value goods dealer (HVGD) and is obliged to register with the Department of Justice Compliance Unit (AML Unit) known as the AMLCU?
The AMLCU website also contains a downloadable Business Risk Assessment template which must be competed by your client annually under Section 30A of the Criminal Justice (Money Laundering & Terrorist Financing) Acts, 2010 to 2021.
As well as registering with the AML Unit, Customer Due Diligence must be applied to the transactions (meaning completing a written risk assessment and obtaining:
- a copy of the customer’s photo I.D. (i.e. a passport or driving licence) and
- a recent utility bill in the name of the customer.
The following documentation requirements also apply to the business:
- Keep the sales order for inspection by the AMLCU.
- Retain records of the method of payment (e.g. cash, cheque, EFT, etc.).
- Complete the cash transaction form designed by the AMLCU for those transactions of €10,000 or more.
- All documentation relating to transactions must be retained for the lifetime of the customer plus 5 years after that.
- Maintain an anti-money laundering (AML) file containing information on money laundering e.g. policies, guides, correspondence, etc.
- Have a written policy statement on money laundering and
- Evidence of recent up to date AML training for all staff.
If your client considers that one of their customers is involved in a suspicious transaction, they are obliged to report it to the Financial Intelligence Unit (FIU) and to the Revenue Commissioners through the relevant reporting channels.
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.
by John McCarthy Consulting Ltd. | Oct 6, 2025 | Blog, News
The CRBOT (Central Register of Beneficial Ownership of Trusts) was created in 2021 to help prevent money laundering and terrorist financing through the use of trusts. It is a register of the names and details of the ultimate beneficial owners of Irish trusts.
In recent years the Revenue Commissioners are concerned that not every trust that should be registered on the CRBOT is actually on the register.
Their CRBOT Team have been conducting compliance-related visits to those acting for trusts, e.g. trust service providers, to ensure they are complying with the CRBOT requirements. While this will apply more to solicitors and law firms, some accountants may also act as trust service providers
The Revenue say that there is a general lack of awareness of CRBOT e.g.:
- The term ‘beneficial owner’ means more than just a beneficiary/ class of beneficiaries.
- The CRBOT Team expect to see a ‘settlor’, so a will trust, or unilateral trust should include this status in the trustee’s nature and extent of interest held.
- Designated persons must check the CRBOT register themselves and retain evidence of that check.
- Where a company acts as a beneficial owner and is registered on the RBO (Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies), their CRO number can be provided to avoid capturing data that is already on the RBO.
Discrepancy Notices must be submitted if designated persons (such as tax advisers) identify factual discrepancies in relation to the trust registers when performing AML due diligence required under AML requirements.
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.
by John McCarthy Consulting Ltd. | Oct 6, 2025 | Blog, News
The Government have been promoting the setting up of innovation hubs around the country in recent years with a 2019 report focusing on the numbers of such hubs available in the Greater Dublin area.
With a significant portion of these innovation hubs now located outside of Dublin, there are over 300 split between
- co-working facilities for life sciences, MedTech, and digital industries; and
- research centres including digital innovation hubs.
These are located in major regional areas such as:
- Cork
- Galway, and
- Limerick
One aspect of these hubs that accountants/auditors may need to make note of is that where these hubs operate as ‘company service providers’ they may need to register as TCSPs (Trust or Company Service Providers) with the Department of Justice AML Unit.
Among other things, the definition of a TCSP includes ‘providing a registered office, business address, correspondence or administrative address or other related services for a body corporate or partnership.’ This will often include the renting of office/desk space and/or meeting rooms.
The latest (1 October 2025) version of the TCSP register is accessible on the AML Compliance Unit’s website here .
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.
by John McCarthy Consulting Ltd. | Sep 12, 2025 | Blog, News
Irish auditors may find some publications of interest on the US Public Company Oversight Board website. They have a section of the website that is focused on supporting smaller audit firms to enhance audit quality which may be found here.
Thera is a series of Staff Publications (including videos) for smaller audit firms called ‘Audit Focus’. Although some of these may have US applicability only, others will be of more general interest to auditors.
For example, there is a January 2025 publication on the audit of Journal Entries arising from staff observations which identify a large number of deficiencies related to the examination of journal entries and other adjustments for evidence of possible material misstatement due to fraud.
Audit Focus highlights key reminders for auditors about testing of journal entries including:
- Obtaining an understanding of the financial reporting process and controls over journal entries and other adjustments.
- Identifying and selecting journal entries and other adjustments for testing to address the potential for material misstatement due to fraud.
- Testing the completeness of the population of journal entries.
- Limiting the testing of Journal entries to meet the fraud criteria set at the planning stage of the assignment.
- Considering the fraud risk potential of manual versus automated journal entries.
- Considering an entity’s controls over journal entries excluding the effectiveness of an entities controls over the general entry process.
- The characteristics of fraudulent entries or adjustments.
- The nature and complexity of the accounts.
- Journal entries or other adjustments processed outside the normal course of business.
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.
