The new AMLR will have an increased impact on AML governance and responsibilities within firms. It requires:
- a strong internal control framework, including policies, procedures, controls,
- a risk assessment, and
- an independent audit function.
The AMLR also clearly defines
- the compliance manager role and
- the officer role,
- with requirements for their
- appointment
- responsibilities, and
- protection from retaliation.
Strengthened Customer Due Diligence (CDD)
The AMLR largely builds on the existing CDD obligations set out in the 4th AML Directive. The existing transaction threshold that triggers CDD obligations for goods was already reduced from €15,000 to €10,000 since 2010.
Under the new rules, obliged entities carrying out occasional cash transactions that exceed €3,000 will also need to apply client/customer due diligence (CDD) measures.
Accountancy Europe has produced a factsheet that summarises the key provisions of the AMLR and highlights their implications for accountants, auditors, and tax advisors.
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.
