ACCA is a Professional Body Supervisor (PBS) for anti-money laundering (AML) in the UK. We welcome the opportunity to provide views on the update to the OPBAS sourcebook that was first issued in January 2018.
The sourcebook is OPBAS’s main channel for providing PBSs with guidance on their expectations on how to effectively comply. We welcome the updated sourcebook as it provides further clarity and detail on OPBAS’s expectations.
We are supportive of the proposals to expand guidance providing examples of the outcomes which can demonstrate effective supervision, as well as the inclusion of examples of practice that OPBAS deems as more or less effective.
However, we have identified some areas of concern in respect of the content in ‘Chapter 6 – Information and Intelligence Sharing’. These areas reflect the issues that were previously raised by the Accountancy AML Supervisors Group (AASG) in February 2022 with OPBAS following the draft publication of the ‘Intelligence and Information Sharing – Good Practice’ note that was developed after the workshops held in November 2021 and December 2021. These concerns are highlighted in our responses to the question raised where appropriate.
As a general comment across the sourcebook, ACCA is of the view that references to ‘members’ throughout would be more consistent with terminology used by the PBSs and it would be more appropriate if the terms ‘supervised firms’ or ‘supervised population’ were adopted.