ACCA is a Professional Body Supervisor (PBS) for anti-money laundering (AML) in the UK. We welcome the opportunity to provide views on the design principles of the economic crime levy and how it could operate in practice in order to ensure that it is proportionate and effective.
ACCA fully supports the UK government in the objectives and goals of the Economic Crime Plan (ECP). In its role as a PBS, ACCA is involved in a number of workstreams of the ECP in order to develop effective and proportionate outcomes for the accountancy sector and the wider financial sector. We fully support 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. ACCA believes that a robust and effective framework to tackle economic crime will help improve and facilitate further commercial activity for businesses in the UK.
Economic crime is a constantly evolving threat globally. It rapidly changes and it affects all in society. We are supportive of UK government initiatives to tackle and combat this and we recognise that further funding is a part of the solution.
Through our own AML Compliance Reviews of ACCA firms supervised for money laundering we see firms playing their part in tackling economic crime through the systems and controls that they have put in place and through meeting their reporting obligations under the Proceeds of Crime Act 2002 (POCA). We welcome the intended improvements to IT supporting the Suspicious Activity Reporting (SARs) system as we have previously highlighted that the current SARs Online reporting system is not fit for the accountancy profession and is outdated. The changes proposed will support our firms to meet their reporting obligations under POCA and also provide a much richer source of reports to aid law enforcement.
ACCA welcomes the proposed Companies House reform to make the data held more robust and transparent. This can reduce the risk of exploitation from those wishing to hide their identity by using UK companies to add a veneer of legitimacy.
However, ACCA believes the levy, currently expected to raise an additional £100 million per year, should be considered for those organisations outside the AML regulated sector which also benefit from initiatives to tackle economic crime. The AML regulated sector consists of around 90,000 entities and it represents a small proportion of the wider population that will benefit from these initiatives. It would therefore seem unreasonable to expect the AML regulated sector to bear the full cost of funding. In our opinion there is an opportunity to explore with other businesses, such as the big technology companies or communications companies, the role they could play in contributing to any levy. Economic crime effects and impacts all of our society. We believe that it is the responsibility of all businesses to contribute towards the levy in their roles as good corporate citizens and not just those companies in the AML regulated sector that can be more easily levied.
To read the full response, please download the consultation document.