by John McCarthy Consulting Ltd. | May 1, 2025 | Blog, News
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:
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.
by John McCarthy Consulting Ltd. | May 1, 2025 | Blog, News
As reported in Accountancy Europe the new EU Anti-Money Laundering Regulation (AMLR) is a major milestone in the fight against money laundering (ML) and terrorist financing (TF).
The AMLR provides detailed guidance on standard, simplified, and enhanced due diligence measures, including:
- Standard CDD Measures: identifying and verifying customer and beneficial owner identities, understanding the business relationship, monitoring transactions, and identifying PEPs.
- Simplified Due Diligence (SDD): applicable in low-risk situations, allowing for reduced scrutiny measures.
- Enhanced Due Diligence (EDD): required for higher-risk scenarios, including dealings with PEPs, requiring additional information gathering and scrutiny.
Outsourcing
The AMLR introduces new detailed rules for obliged entities that outsource their AML/CFT tasks, distinguishing the term ‘outsourcing’ clearly from reliance on other obliged entities
Enhanced obligations on beneficial ownership transparency
The requirements for due diligence on beneficial owners have been strengthened, with a refined definition of beneficial ownership to clarify the framework for identifying individuals who ultimately own or control legal entities and arrangements. Ownership interest in a corporate entity is determined by a threshold of 25% or more of shares, voting rights, or other ownership interests.
Obliged entities must also verify whether the customer or beneficial owners are subject to targeted financial sanctions (TFS).
A new definition for politically exposed persons (PEPs)
The AMLR expands the definition of PEPs to encompass “heads of regional and local authorities”, as well as “groupings of municipalities and metropolitan regions”. It also specifies that, for the functions of heads of state, heads of government, ministers, deputy or assistant ministers, and equivalent roles at the Union level or in third countries, siblings are also considered ‘family members’.
EU-wide ban for large cash payments
The Regulation imposes an EU-wide maximum limit of €10,000 for cash payments, whether in single or linked transactions. Member States may set lower limits.
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:
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.
by John McCarthy Consulting Ltd. | Apr 18, 2025 | Blog, News
This is the first in a series of three blogs looking at the new AML legislation expected across Europe by 2027.
As reported in Accountancy Europe the new EU Anti-Money Laundering Regulation (AMLR) is a major milestone in the fight against money laundering (ML) and terrorist financing (TF).
The AMLR will substantially impact accountants’, auditors’ and tax advisors’ – and all other so-called obliged entities – daily operations and compliance obligations in the areas of customer due diligence, beneficial ownership transparency, compliance with targeted financial sanctions, suspicious activity reporting, and record retention.
Impact and scope
The AMLR marks a shift from directives (which gave member states choices in implementation methods) to direct application, meaning consistent enforcement across the EU. It affects a broad range of ‘obliged entities’ in financial and non-financial sectors including accountants, auditors, and tax advisors.
The legislation came into effect on 9 July 2024 and will apply from 10 July 2027. This gives professionals time to review and update their existing policies and practices to meet the new requirements. Given the AML rules’ volume and extent of detail, early preparation is crucial for practitioners to assess and plan for the changes ahead.
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:
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.
by John McCarthy Consulting Ltd. | Apr 18, 2025 | Blog, News
In case you haven’t already heard designated persons (that includes accountants in practice) have a new regulator called the ‘Authority for Anti-Money Laundering and Countering the Financing of Terrorism’. Originally created in June 2024, the Board held its first meeting in March 2025 and the chair is Bruna Szego.
The aim of this new authority is to coordinate national AML authorities around Europe to ensure the correct and consistent application of AML rules in each jurisdiction.
AMLA will also supervise supervisory bodies in Europe including the Institute and enhance cooperation among police financial intelligence units (FIUs).
Ms Szego will be at the RDS in Dublin in May to give the Keynote Address at the European Anti-Financial Crime Summit 2025.
It’s expected that AMLA will be fully operational by 1 January 2028 with a staff complement of 430.
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.
by John McCarthy Consulting Ltd. | Apr 3, 2025 | Blog, News
If you have corporate clients in the UK, you may wish to register with Companies House as an Authorised Corporate Service Provider (ACSP). This is a new requirement driven by the rise in money laundering and fraud using corporate structures. ACSPs are also known as Companies House Authorised Agents.
The ACSP initiative is being rolled out in stages. Stage 1 commenced on 8 April 2025, when the service allowed authorised agents, such as accountants, to verify clients’ identities for Companies House purposes. Records of the identity checks need to be retained by the agents for 7 years.
File as an Authorised Agent
The next stage will commence in Spring 2026, when authorised agents will be able to file on behalf of clients.
An authorised agent can be a business (for example, a limited company or partnership), or a person who files on behalf of others (a sole trader).
To register, agents must be supervised by a UK Anti-Money Laundering (AML) supervisory body such as Chartered Accountants Ireland. In the future, all businesses that file information on behalf of clients will need to register as an ACSP.
For more information and to start the registration process follow this link.
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.
