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:
- Our latest CPD Webinar on The Main Changes in Irish GAAP (recorded July 2024)
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- AML Webinar (December 2023) available here, which accompanies the AML Manual. It explains the latest legal AML reporting position for accountancy firms and includes a quiz. Upon completion you receive a CPD certificate for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
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.
