ACCA whistleblowing policy
ACCA has set up a dedicated whistleblowing hotline and email address for those who wish to make a report about an ACCA member or firm. These have been set up so that ACCA can be more easily alerted about instances of non-compliance with the anti-money laundering regime, or potential involvement in money laundering or terrorist financing by ACCA members or firms.
ACCA is committed to supporting anyone who wishes to make a confidential report about an ACCA firm, member, affiliate or student, where it is known or suspected that they:
a) Should be regulated under the Money Laundering Regulations, but are not; or
b) Appear to be ignoring the MLRs; or
c) Appear to be engaged (whether inadvertently or knowingly) in money laundering or terrorist financing.
If you wish to report an individual or firm whose supervisor for AML is ACCA you can report the matter confidentially to ACCA.
ACCA encourages timely, responsible and lawful reports about what you know or suspect. Your report could help identify, stop or prevent reckless or dishonest behaviour which might pose a risk to the public.
Anyone wishing to make a report to ACCA may withhold their identity completely. However, ACCA would encourage everyone making a report to provide contact details to allow us to obtain further information if required.
ACCA appreciates that there may be circumstances which make it difficult to openly report the behaviour of a person or firm who is known or suspected to be involved in money laundering and terrorist financing. Whatever the reason for the difficulty, ACCA would still encourage you to make a report.
Any reports received, whether anonymous or open will be assessed by an anti-money laundering specialist. ACCA will then decide upon the most appropriate way to use the information provided. The information provided may for example influence the risk assessment of a firm, or may result in a supervisory visit, or may lead to a complaints and disciplinary investigation. This may also lead to ACCA’s Money Laundering Reporting Officer filing a Suspicious Activity Report with the National Crime Agency.
Members are generally entitled to know the identity of the person making a report against them. However, given that sometimes this is not appropriate, you may request that ACCA refrain from sharing your identity with the member.
In circumstances where your identity may or is likely to be immediately apparent when the report is communicated to the member, ACCA will refrain from notifying the member without discussing the matter with you first.
If ACCA cannot disclose the identity of the maker of a report, ACCA may be unable to take any action in relation to the conduct reported Other than filing a Suspicious Activity Report.
We may still retain records of your identity within our own records, and these may be shared with our providers should there be an investigation. Information about you, or which you provide to us, may be disclosed to other parties such as the National Crime Agency and OPBAS.
The party named in your report may also make a subject access request to ACCA (see our FAQs on whistleblowing for further information), which may require us to disclose additional information relating to them. This right of access is subject to some exceptions, so please let us know any concerns in disclosing information you have provided. We will seek to maintain your anonymity where you have asked us to do so.
ACCA may also share the information you provide with other regulatory bodies where the report is about someone with dual membership, as well as the regulators that have oversight of ACCA.