CCAB anti-money laundering guidance updated for new legislation

ICAEW and other CCAB bodies have updated their joint anti-money laundering guidance to reflect new legislation. This legislation transposes the 4th European anti-money laundering Directive into UK law with effect from 26 June 2017.


The updated guidance is at AML – the essentials: September 2017. Treasury approval of this guidance is being sought.


ICAEW members who receive the Institute’s Practicewire email will already be aware that the new legislation makes several changes including:


  • A more prescriptive approach to firm-wide risk assessment: there is a requirement for a written risk assessment and a list of factors that firms must take into account.
  • Firms must now appoint a sufficiently senior money laundering compliance principal (MLCP) where appropriate to the size and nature of the business. This can be the existing money laundering reporting officer (MLRO) if the MLRO is sufficiently senior. Sole practitioners with no employees are exempt from this requirement.
  • Three key changes to customer due diligence (CDD) requirements:

1. firms must now also complete CDD where they perform one-off company formation services;

2. firms must also identify and verify persons purporting to act on behalf of their client; and

3. firms must obtain and verify the name of the body corporate, its registration number, its registered address, and principal place of business, and must also take reasonable measures to determine and verify the law to which it is subject, its constitution (set out in governing documents) and the names of the board of directors and its senior management.


As noted in our previous news item highlighting the regulations, there are several other new provisions, which are summarised in ICAEW’s overview of the changes in Money Laundering Regulations 2017.