1. Introduction
FM Accounting Ltd is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy is established in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) and the Proceeds of Crime Act 2002.
As an accountancy service provider, we are supervised for AML compliance and are required to implement and maintain appropriate policies, controls, and procedures to prevent money laundering and terrorist financing.
2. Customer Due Diligence (CDD)
We are required to verify the identity of all clients before establishing a business relationship. Our CDD procedures include:
- Identification: Obtaining the client's full name, date of birth, residential address, and nationality
- Verification: Verifying identity using reliable, independent source documents (e.g., passport, driving licence, utility bill)
- Beneficial Ownership: Identifying and verifying the beneficial owners of corporate clients (individuals holding 25% or more ownership or control)
- Purpose of Relationship: Understanding the nature and intended purpose of the business relationship
We will not proceed with providing services until satisfactory CDD has been completed.
3. Enhanced Due Diligence (EDD)
Enhanced measures are applied in higher-risk situations, including:
- Clients who are Politically Exposed Persons (PEPs) or their family members and close associates
- Complex or unusual ownership structures
- Clients from high-risk jurisdictions (as identified by FATF or HM Treasury)
- Transactions that are unusually large or complex without apparent economic purpose
- Where there are concerns about the source of funds or wealth
EDD includes obtaining additional documentation, conducting enhanced background checks, and obtaining senior management approval.
4. Ongoing Monitoring
We conduct ongoing monitoring of all client relationships, which includes:
- Reviewing transactions to ensure they are consistent with our knowledge of the client's business
- Keeping CDD information up to date, particularly for higher-risk clients
- Conducting periodic reviews of client risk assessments
- Monitoring for unusual or suspicious activity
5. Suspicious Activity Reports (SARs)
Where we know or suspect that a client or any person is engaged in money laundering or terrorist financing, we are legally required to:
- Submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA)
- Not inform the client or any third party that a report has been made ("tipping off" is a criminal offence)
- Seek consent from the NCA before proceeding with the relevant transaction if applicable
6. Record Keeping
We maintain records in compliance with the Regulations:
- CDD records: Retained for at least 5 years from the end of the business relationship
- Transaction records: Retained for at least 5 years from the date of the transaction
- Training records: Retained for the duration of employment plus 5 years
- Records are stored securely and in compliance with data protection legislation
7. Staff Training
All relevant staff receive AML training:
- Upon joining FM Accounting Ltd
- At regular intervals thereafter (at least annually)
- When there are significant changes to regulations or our procedures
Training covers recognising and reporting suspicious activity, CDD requirements, and the legal framework for AML/CTF.
8. Risk Assessment
We conduct a firm-wide risk assessment that considers:
- Client risk: Nature of client, industry sector, country of origin
- Service risk: Types of services provided and their susceptibility to money laundering
- Geographic risk: Countries and regions involved in transactions
- Delivery channel risk: How services are delivered (face-to-face vs. remote)
The risk assessment is reviewed and updated at least annually or when material changes occur.
9. Nominated Officer
FM Accounting Ltd has appointed a Nominated Officer (also known as the Money Laundering Reporting Officer, or MLRO) who is responsible for:
- Receiving and assessing internal suspicious activity reports
- Determining whether SARs should be submitted to the NCA
- Maintaining records of all reports received and actions taken
- Ensuring the firm's AML policies and procedures are up to date
- Overseeing AML training
10. Non-Compliance
Failure to comply with AML/CTF regulations is a serious criminal offence. Penalties include unlimited fines and imprisonment. FM Accounting Ltd takes a zero-tolerance approach to non-compliance by any staff member.
11. Contact
If you have any questions about our AML policies or procedures, please contact us at info@fmaccounting.net.