by John McCarthy Consulting Ltd. | Jan 11, 2021 | Blog, News
When you are doing your Client Due Diligence on a new client/customer, did you ever wonder where you could obtain a list of sanctioned or high-risk territories/jurisdictions?
Well, a reliable source is near at hand. The Financial Action Task Force (FATF) identifies jurisdictions with weak measures to combat money laundering and counter terrorist financing (AML/CFT) in two FATF public documents. These two reports identify:
These reports are issued three times a year in February, June, and October.
The FATF’s process to publicly list countries with weak AML/CFT regimes has proven to be effective. For example, as of October 2018, the FATF had by then reviewed over 80 countries and publicly identified 68 of them. Of these 68, over 80% have since made the necessary reforms to address their AML/CFT weaknesses and have been removed from the process.
The first public document, the FATF’s Public Statement, identifies countries or jurisdictions with such serious strategic deficiencies that the FATF calls on its members and non-members to apply counter-measures. These include enhanced due diligence measures proportionate to the risks arising from the deficiencies associated with the country.
The statement “Improving Global AML/CFT Compliance: On-going process” identifies countries or jurisdictions with strategic weaknesses in their AML/CFT measures, but that have provided a high-level commitment to an action plan developed with the FATF. The FATF encourages its members to consider the strategic deficiencies identified for these jurisdictions.
If any country fails to make sufficient or timely progress, the FATF can decide to increase its pressure on the country to make meaningful progress by moving it to the Public Statement.
For more information about the FATF’s process to identify high-risk and non-cooperative jurisdictions and monitor their progress, click here.
Watch out for our 2021 update to the AML Policies & Procedures Manual coming soon.
For a complete list of our time-saving engagement letter templates for FRS 102 audit, FRS 102 audit-exempt, VAT, visit our store here. All our engagement and representation letter templates are up to date for Brexit and Covid 19.
by John McCarthy Consulting Ltd. | Apr 20, 2020 | Blog, News
Cybercrime is not without victims and is taken extremely seriously by law enforcement.
Teenagers can drift into cyber-crime without realising the seriousness of their actions. In a timely video message from the UK National Crime Agency (NCA), parents are warned about the crimes teenagers can get involved in, especially during COVID-19 confinement.
The NCA have put together a series of online resources aimed at students/parents/guardians/carers and teachers. Coding, programming and computing are great skills to learn, but only if used safely.
The Garda Síochána have similar resources available at the Garda National Cyber Crime Bureau (GNCCB) website.
The Garda site also includes advice on the most common forms of money laundering during this Coronavirus era such as ransomware, spoof bank websites, Investment scams and CEO fraud, among several others.
Now is a good time to tighten up your AML procedures. For our latest 2020 Anti-Money Laundering Policies & Procedures Manual (retails for €150+VAT) see our online store here.
The Manual contains everything you need to successfully implement the requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 and the Register of Beneficial Ownership.
Comes with a, free of charge, Excel spreadsheet called the ‘AML Control Sheet’ which firms may use to give a ‘helicopter’ view of progress made with keeping client AML data up to date.
Catch up on your AML CPD training here with webinars (all at €45 each and available on demand) on various AML topics like:
by John McCarthy Consulting Ltd. | Feb 27, 2020 | Blog, News
We have just published an update to the AML Policies Controls & Procedures Manual last week, which is available to purchase now on our website. Our latest February 2020 edition includes the following updated items:
- Pronouncement by the FATF arising from their Public Consultation on FATF Draft Guidance on Digital Identity (discussed at the FATF plenary meeting in Paris from 19-21 February 2020)
- The latest developments on the RBO register since June 2019
- Further guidance on carrying out electronic searches and the validity of sourcing electronic data for client identity purposes.
This Manual contains everything you need to successfully implement the requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 which became law on 26 November 2018 and the Register of Beneficial Ownership which came into effect on 22 June 2019.
This Manual comes with a, free of charge, Excel spreadsheet called the ‘AML Control Sheet’ which firms may use to give a ‘helicopter’ view of progress made with keeping client AML data up to date.
The Manual includes eleven Appendices with templates/guidance on how to implement the legislation efficiently. It retails for only €150+VAT and may be downloaded, ready to use, in Word format.
by John McCarthy Consulting Ltd. | Nov 25, 2019 | Blog, News
In a recent Financial Times story, it was reported that the EU is proposing to set up a new anti-money laundering body in the wake of recent money laundering scandals.
EU finance ministers are expected to meet in December and propose the setting up of a new independent body to enforce money laundering prevention measures across the EU.
The proposal would trigger a significant increase in the response to a wave of money-laundering scandals that have occurred since 2017. These scandals have revealed weaknesses in the EU banking system which have been exploited by criminals.
The two most notable recent scandals have involved two of Europe’s most high profile banks: Danske Bank and Deutsche Bank.
US law enforcement authorities uncovered institutionalised money laundering in 2018, at the now defunct Latvian bank ABLV — much of it linked to Russia. This was just one in a series of serious blows to European confidence in its banking system’s defence against crime.
Another setback involved revelations that €200bn in suspicious transactions had been moved through Danske Bank’s Estonian branch. ING was fined €775m for compliance failings and Deutsche Bank was ensnared in a scheme to illicitly shift criminal funds from Russia to the west.
For our latest AML Training webinar for Accountants go to this link and for Trust and Company Service Providers go to this link.
All 19 training webinars are listed here and on completion you receive a CPD certificate by email.
We also publish a completely up to date AML Policies & Procedures Manual 2019 which includes a template for the Business Risk Assessment which each AML supervised business must have in place since 26 November 2018 under the latest legislation which is the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018. This manual retails for only €150+VAT and may be downloaded, ready to use, in Word format.
We also sell several letters of engagement and other templates which all comply with the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018.
by John McCarthy Consulting Ltd. | Mar 5, 2019 | Blog, News
In spite of efforts to make UK registered companies disclose their ownership through the people with significant control (PSC) register, thousands of companies don’t comply with the rules brought in to counter fraud and money laundering.
According to a 2018 Freedom of Information request to Companies House by Fortytwo Data (now Napier), over 57,000 UK businesses are not yet compliant with new regulations.
Similar requirements are in the process of being introduced in Ireland, called the Beneficial Ownership Register to be maintained by the Companies Registration Office (CRO), as part of the enforcement of the EU Fourth AML Directive.
It is a criminal offence not to follow the PSC/Beneficial Ownership requirements, with potential sanctions including fines for the companies involved and up to two years in prison for the culpable individuals.
PSCs/Beneficial Owners, are natural persons who own directly or indirectly at least 25% of a company’s shares or control at least 25% of its voting rights, or have control over appointments to the board of directors.
The PSC/Beneficial Ownership Registers are designed to reduce the ability of money launderers to hide and funnel their ill-gotten gains, using apparently legitimate corporate structures.
For more up to date information on developments in company law and anti-money laundering, visit the new online webinar training section of our website. Once viewing is completed customers will receive a CPD Certificate confirming their learning.
