ACCA is a Professional Body Supervisor (PBS) for anti-money laundering (AML) in the UK. We welcome the opportunity to provide views on the government’s approach and plans for amending the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). Our response to this consultation has been informed by input obtained from our supervised population and discussions with other accountancy PBSs.
ACCA fully supports the development of an effective UK AML regime that provides confidence in the UK as a safe, transparent and compliant jurisdiction to conduct business in. We believe that a robust and effective framework to tackle economic crime will help improve and facilitate further commercial activity for businesses in the UK.
We are generally supportive of the proposed changes to the MLRs to ensure that the legislation remains proportionate and effective. For example, we welcome the inclusion of specific legal requirements in relation to Suspicious Activity Reports (SARs) will enable supervisors to enhance the performance of their supervisory functions.
However, we have identified some areas of concern and these are highlighted in our responses to the questions raised where appropriate. In particular, we have concerns about potential amendments in relation to SARs and the reporting of discrepancies that may have unintended consequences and create additional burdens on supervisors, supervised populations and other agencies. We would therefore encourage HMT and the government to engage in further conversations and work to provide clarity on expectations and areas of concern, identify practical solutions, and ensure a consistent approach across the PBSs.
To read the response in full, please download the consultation response document.