Employee Integrity under the Proposed New AMLR
We saw last week that the proposed new AML Regulation AMLR places additional emphasis on AML training for employees and others.
This week we look at Article 13 of the EU AML Regulation AMLR which mandates regular assessments for individuals responsible for an obliged entity’s AML/CFT compliance.
Such personnel must be regularly evaluated on their:
- Skills
- Knowledge
- Expertise
- Integrity, and
- conduct
The assessments carried out must be performed on new personnel prior to taking up responsibility for AML compliance activities, including agents and third parties. The intensity of the subsequent assessments shall be risk based and determined on the basis of the tasks entrusted to the person and risks associated with the function they perform.
Conflicts of interest
Conflicts of interest must be avoided, and employees must disclose any close personal or professional relationships with the entity’s current/prospective clients to the compliance officer.
The firm must have procedures in place to prevent such staff from being involved in compliance tasks related to these clients.
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.
