AML Training in the Proposed New AMLR

AML Training in the Proposed New AMLR

by | May 18, 2025 | Blog, News

The proposed new EU Anti-Money Laundering Regulation (AMLR) is expected to be effective in Ireland in 2027. This week we look at one aspect of that Regulation relating to AML training.

Article 12 of the AMLR places greater emphasis on AML Training which is a more comprehensive requirement than in the 4th AML Directive. The 4th AML Directive only required AML training for the obliged entity’s employees who were involved in AML compliance.

Under the new proposed AMLR, accountancy firms must ensure that all individuals involved in implementing AML/CFT measures receive adequate training. The reach of the AML training requirement will be much wider than heretofore and accountancy firms will be held to account in a more comprehensive way for their AML training responsibilities.

Those that will need to have the AML training under the AMLR include:

  • Employees;
  • Agents; and
  • Third party contractors.

The AML training should enable these personnel to recognise potential ML/TF activities and know what steps to take when they encounter them.

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 MLRO’s Annual ‘Health Check’ – Part 1

The MLRO’s Annual ‘Health Check’ – Part 1

by | Aug 8, 2024 | Blog, News

Every accounting firm is obliged to carry out money laundering checks on clients and support these checks with appropriate documentation.

In this two-part blog we are going to look at the main focus of the Money Laundering Reporting Officer (MLRO). Practically speaking, for smaller firms the MLRO is the sole practitioner – the buck stops with you.

The MLRO should at least annually document how the AML internal quality control process operates.  Ideally, this might be in the form of a memo or in a report from an external provider.

The report should include the following aspects:

  1. Executive summary for the year highlighting any serious compliance deficiencies, together with details of the remedial action that has been taken.
  2. Review the number and quality of internal Suspicious Transaction Reports (STRs) and consider more focused training where none have been received.
  3. Number of external STRs submitted to the Garda on GoAML and the Revenue on ROS.
  4. Number of new clients declined because of unsatisfactory information.
  5. Details of staff training during the year including –
    • Number of AML courses
    • Details of new/existing staff attending;
    • Issues/queries/misunderstandings clarified
    • Supporting evidence of AML training and proof of understanding with documented quiz assessment results and supporting attendance certificates.

See more in next week’s blog.

In the meantime, please go to our website to see our:

  • 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, please contact John McCarthy FCA by email at john@jmcc.ie.
  • We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.
After the AML Inspection – 5 Most Important Things to Do (and 2 Things NOT to Do)

After the AML Inspection – 5 Most Important Things to Do (and 2 Things NOT to Do)

by | Apr 27, 2024 | News

So you’ve had an AML inspection from your professional body. Now it’s time to pick up the pieces.

Do:

  1. Respond in good time to enquiries from the reviewer (even if it’s merely to acknowledge receipt of correspondence).
  2. Ensure that the information you supply to the reviewer is meticulously accurate and complete.
  3. If asked to select documents relating to clients for submission to the reviewer, select those clients with care, review the documents before submitting them, and provide additional explanations of these documents to the reviewer if that may help.
  4. Keep a copy of everything you submit (or request a copy from your supervisory body if you do not have a copy).
  5. If you are not confident that your AML procedures are fully satisfactory, consider obtaining external assistance before responding to the reviewer.

 DON’T:

  1. Backdate or falsify any documents to be submitted for review.
  2. Waste the reviewer’s time with incomplete or half-baked responses hoping to buy extra time. If you have insufficient time, simply ask for more time at the earliest possible stage of the process.

All our CPD courses are listed here, including our Audit Update webinar.

To hear more about the latest AML developments and how to be on the alert for suspicions of money laundering and terrorist financing under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, see our latest Anti-Money Laundering webinar here.

Please also go to our website to see our:

  • Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • 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 of attendance in your inbox.
  • letters of engagement and similar templates. Please visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
  • ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by e-mail at john@jmcc.ie.
  • We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.
6 Essentials to Prepare for an AML Compliance Review

6 Essentials to Prepare for an AML Compliance Review

by | Apr 17, 2024 | News

If you have an upcoming AML Compliance Review from your professional body, be sure to follow these six essential steps to prepare.

  1. Ensure that you have an appropriate Policies & Procedures document and a Firm-Wide Risk Assessment accompanied by a note of annual reviews of and amendments to the assessment.
  2. Ensure that relevant staff have received money laundering training accompanied by a record of training completion.
  3. Carry out some test checks of records of your client Risk Assessments and Client Due Diligence documentation to assess whether the firm’s Policies & Procedures are being properly implemented.
  4. Check whether an external AML Compliance Review beforehand might be beneficial.
  5. Check that the information held by your supervisory body about the firm and its MLRO are up to date and correct according to the firm’s most recent Annual Return.
  6. Ensure that all the work which the firm is doing is correctly licensed under the terms of the firm’s authorisation from your supervisory body (e.g. insolvency work and Clients’ Money).

Following these six steps will ensure that your firm is well prepared for its AML Compliance Review.

All our CPD courses are listed here, including our Audit Update webinar.

To hear more about the latest AML developments and how to be on the alert for suspicions of money laundering and terrorist financing under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, see our latest Anti-Money Laundering webinar here.

Please also go to our website to see our:

  • Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • 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 of attendance in your inbox.
  • letters of engagement and similar templates. Please visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
  • ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by e-mail at john@jmcc.ie.
  • We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.