The Money Laundering Regulations 2007 come into force on 15 December 2007, and revoke the 2003 Regulations.

With this latest round of legislation there is more emphasis on firms having the correct systems and procedures in place, with the following ongoing activities being given specific mention:

• Customer due diligence
• Monitoring of clients’ activities
• Employee training

Furthermore, the new regulations widen the boundaries for who is caught under the regulations, with un-qualified accountants now coming under the jurisdiction of their nominated supervisory body, HMRC, from December.

As with the 2003 regulations, failure to comply could result in the principals in the firm committing a criminal offence, which could include a jail sentence and/or fines.

Specific changes to the 2007 Regulations include:

• A mandatory risk-based approach to customer due-diligence on all clients, including those that have been clients since before the initial deadline of 1 March 2004
• Customer due diligence includes the need to identify beneficial owners and take appropriate risk-based measures to verify them
• Firms will be supervised by their professional body, which must ensure compliance with the regulations
• An extension of policies and procedures to include ongoing monitoring, internal control, risk assessment and management, and managing compliance
• All relevant employees must undertake ongoing training on the money laundering regulations and recognising and dealing with suspicious activities

At the time of writing, we are still awaiting the final guidance notes form the CCAB. Copies of the exposure draft can be downloaded from their website at www.ccab.org.uk.

To bring you up to speed with the new regulations we have various training courses, products and services what can help you. These include:

• Public money laundering courses running from 27 November at various venues. For dates, venue details, and the course outline click here.
• Our new online money laundering training course, helping you get up to speed with the 2007 Money Laundering Regulations for just £35+VAT per person. Click here for details and to enrol.
• A CD version of the on-line training course, with a multi-user licence. The training CD costs £99 + VAT. Click here for details and to order your copy.
• In-house courses including: Money Laundering Introductory Training; Money Laundering Update; and the Money Laundering Clinic – should you have several people you want to be trained in one go. Contact us for availability and pricing information.
• The procedures manual. At £99 + VAT the manual has guidance notes, checklists and templates to help you set up and maintain the correct systems in your practice.
• Compliance reviews – on site visits to check your systems and make recommendations, where necessary, to ensure you’re complying with the new regulations. The on-site visit, including the recommendations report, costs £1030 + VAT.
• The MLRO Support Service – a 12-month subscription package consisting of the training CD (with access for your MLRO and Deputy MLRO to use the on-line training facility); the procedures manual; two hours of money laundering technical queries; and our highly regarded monthly email newswire. This great value, ongoing support package costs £37 per month, with discounts available for SWATUK Full and Reduced Members.

For further details on any of our practical money laundering products and services, please contact us on 0845 450 5555. Alternatively, use our ‘contact us form’, stating your interest in money laundering support, and we will contact you instead.

Vicki Banthorpe
November 2007