MLR3C10375 - Accountancy Service Providers (ASPs): specific compliance checks at a visit to an ASP

The CCAB guidance at Section 5.42 onwards stresses the importance of “Know your Client” (KYC) which should be at the forefront of an effective anti money laundering policy put in place by an ASP. To demonstrate compliance with MLR 2007 an ASP must show that it has identified its customers by carrying out appropriate customer due diligence checks. It is also necessary to demonstrate that sufficient information about the trading activities of the client has been obtained so that a risk assessment of the client can be carried out in relation to possible involvement in money laundering activity. Once an assessment has been put in place ongoing monitoring should be carried out to confirm that the risk has not altered.

In addition to these checks an ASP is also required to demonstrate that it complies with the Regulations with regard to retention of records and the submission of Suspicious Activity Reports (SARs). Where the ASP has staff the regulations relating to MLR training should be tested.