Anti money laundering guidance

All members need to be familiar with the issue of money laundering and the importance of reporting any suspicions. They need to be aware of the current legislation in their own countries, as well as the legislation of the country in which they are working, or of those countries with extra-territorial powers.

UK members working in certain types of business (including trust and company service providers, casinos), or who fit the new definition of 'external accountants', will be particularly affected by the new regime.

‘An external accountant’ is described by HM Treasury in the Money Laundering Regulations 2007 as ‘any person who by way of business provides accountancy services.’ The term ‘external accountants’ excludes accountants employed by—

(a) public authorities; or
(b) undertakings which do not by way of business provide accountancy services to third
parties.

Under the Money Laundering Regulations, professionals who act as insolvency practitioners, tax advisers, trust and company service providers and providers of accountancy services are included as relevant businesses.

Individuals or businesses involved in the provision of management consultancy services, or interim management, should be alert to the possibility that they are also likely to come within the scope of the legislation because they may supply the service of forming, operating or managing companies, or provide accountancy services.