Calling time on non-compliance with AML requirements: New guidance published

As accountants play a key role in fighting economic crime, it’s important that our members take a diligent approach to their anti-money laundering responsibilities. We will therefore introduce revised AML Regulatory Actions Guidance document from 7 April 2025.

 2017, the Money Laundering Regulations introduced a range of new requirements for professional service firms, including accountants, auditors and insolvency practitioners, significantly impacting how clients should be handled throughout the lifespan of a business relationship.

Since then, both at a UK and international level, there has been an increased focus on the harms of economic crime and the part that professional service firms can play in that, either deliberately or unwittingly. With ICAS’ focus on ethical leadership, it’s right that we and our supervised firms play an important part in this fight.

Our AML monitoring visits demonstrate that supervised firms are mostly compliant and are undertaking their responsibilities diligently. However, some firms still aren’t paying sufficient attention to the requirements, so we must now take a more robust approach in these circumstances.

The ICAS Authorisation Committee has recently approved changes to its approach to dealing with AML non-compliance, as set out in its AML Regulatory Actions Guidance document.

The new guidance – which will be used by the Committee from 7 April 2025 onwards – changes the approach in two main ways:

1. Tariffs – the guidance will now include indicative regulatory penalties in response to eight categories of non-compliance, including failures in relation to customer due diligence and firm-wide processes.
2. Timing – to make the process more efficient, AML non-compliance will be considered by the Committee at the earliest opportunity following identification on a monitoring visit.

ICAS will continue to be proportionate in its supervisory approach, offering support to firms to help them meet the required standards. We only expect financial penalties to be applied where firms have not given the AML requirements appropriate attention, including failures to take appropriate action in response to issues identified in previous monitoring visits.

Supervised firms are encouraged to review the eight categories of non-compliance in the guidance and take immediate action if there are any areas whether further work is required to achieve compliance. More information on common findings from AML monitoring visits can be found in the AML report we published at the end of October 2024.

To further assist firms, ICAS will be extending the level of AML support which is provided, including articles, videos, and other communications.