ACCA AAA ^INT Syllabus A. Regulatory Environment - How Accountants Prevent Money Laundering - Notes ^{7 / 11}

The following will prevent their organisations being used for money laundering purposes

1. Establish a top-down anti-money laundering culture

2. Have risk management procedures & internal controls

3. Appoint a money laundering reporting officer (MLRO)

4. Have record keeping systems for all transactions

5. Keep systems for initial verification and continued monitoring of clients' identities

6. Have internal suspicion reporting procedures

7. Educate and train all staff in the main requirements of 
the legislation

Money Laundering Reporting Officer

Basically should have a suitable level of seniority and 
experience

• If the MLRO is away then a deputy must be appointed (as reports must be made as soon as practicable)

• Sole practitioners do not need to appoint an MLRO

• Responsibilities Include

  • Internal reports of money laundering

  • Deciding if sufficient grounds for suspicion

  • Preparing the external report to present to the appropriate authority

  • Key liaison individual with the authorities

  • Advising the engagement individual/team on how to continue their work and interact with the client

  • Training on ML matters

  • Designing anti-ML systems