imagesMoney Laundering Policy

The Dentdale Bookkeeping Company has policies and procedures to ensure compliance with all aspects of the Money Laundering Regulations 2017. We are committed to following all of the Regulations’ requirements and to promoting a culture of compliance throughout the Company.

• Money laundering is addressed properly in all assignments that the Practice performs.

• Commercial factors never override the need to comply with the Regulations.

• Sufficient resources are devoted to the implementation, documentation and training necessary to ensure compliance.

• A suitable money laundering reporting officer (MLRO) and, where applicable, a money laundering compliance principal (MLCP) monitor compliance.

Due Diligence

Policy

• The Practice will undertake a risk assessment and obtain the required forms of identification for all new clients.

• This evidence will be obtained before commencing work for a client.

• The evidence will be updated whenever a change occurs or before undertaking a new assignment.

• Where evidence is not available, it shall be the responsibility of the MLRO to decide how to proceed.

Procedures

• Due diligence will be undertaken on all new and existing clients on an ongoing basis. This exercise will involve considering the operation of the business and undertaking appropriate identification checks.

• The following forms will be completed in order to demonstrate compliance:

1. Client Risk Assessment form – AML online

2. Client Due Diligence record – AML online

3. Money Laundering Internal Report (MLR4)

4. MLRO Control Sheet (MLR5)

5. MLRO Report Log (MLR6)

6. Training Record (MLR7)

Money Laundering Reporting

Policy

• The Practice will report to the National Crime Agency (NCA) any suspicious activity that is identified.

Procedures

• Any suspicious activity shall be reported to the MLRO, or alternate, as soon as that suspicion arises.

The report will be made using the internal reporting form, completing all the relevant details. This report shall not be discussed with anyone apart from the MLRO, or alternate. At no stage must the client be given any details of the report.

• On receipt of the report the MLRO, or alternate, will consider its contents, requesting further information where required. It shall be the responsibility of the MLRO to decide what activity is suspicious.

• Any such activity shall be reported to the NCA in the prescribed form.

• The decision will be recorded on the internal report form.

• At this stage the MLRO will inform the partner in charge, or MLCP where applicable, of the assignment of any action that he needs to take.

Record Keeping

Policy

• The Practice will maintain records of identification and consideration of money laundering issues for the entire period that the Practice acts for a client and for six years after it ceases to act.

Procedures

• Client Due Diligence details will be completed on AML online for all new clients and updated on at least an annual basis.

• The supporting documentation will be filed in an appropriate place.

• When ceasing to act for the client this information will be archived and kept in a secure location. It will be passed for confidential destruction after six years.

Internal Control

Policy

• The Practice will facilitate adequate internal control to allow for compliance with the regulations.

Procedures

•The MLRO/MLCP shall be responsible for implementing any necessary changes to the Practice’s procedures to ensure compliance.

• All partners and staff will be required to accept the authority of the MLRO/MLCP.

• All partners and staff of the Practice, including sole practitioners, will be required to make the necessary internal reports using the form within this manual when they have a suspicion in respect of a client.

Risk Assessment and Management

Policy

• The Practice will undertake a risk assessment for all clients on at least an annual basis but with new and changing risks considered as and when they are identified. Resources will be focused on the areas of greatest risk and a risk-based approach will be adopted.

Procedures

• AML online Risk Assessment and Client Due Diligence details will be completed for all clients and reviewed and updated where necessary.

Compliance Management

Policy

• The Practice will undertake a regular compliance review to ensure that the requirements of the regulations are being followed.

Procedures

• The MLRO/MLCP shall undertake a compliance review on a regular basis. This review will include (as applicable):

• Consideration of the annual declaration of fit and proper status completed by all partners and staff.

• A review of a sample of files to ensure that due diligence has been completed and updated as necessary.

• Consideration of the adequacy of the training given to all staff and partners.

• Client Due Diligence details will be completed on AML online for all new clients and updated on at least an annual basis.

• The supporting documentation will be filed in an appropriate place.

• When ceasing to act for the client this information will be archived and kept in a secure location. It will be passed for confidential destruction after six years.

Communication

Policy

• The Practice will ensure that all partners and staff have access to adequate training regarding the Regulations and the Practice’s policies and procedures.

Procedures

• All partners and staff will be required to undertake an update course for the new Regulations.

• All partners and staff will be required to consider the need for further training during the annual appraisal process.

• Personnel will be required to confirm their understanding of and compliance with the Regulations and the Practice’s policies and procedures as part of their annual declaration.

ICB_Crest_EPS_Colour.eps
Practice Licence Number 20566

VAT Reg No 307 9581 79