When an accountancy practice submits an external suspicious activity report (SAR), it must turn information from the client engagement into financial intelligence that law enforcement can understand and use. The narrative needs to identify the relevant people, activity, and suspected criminal property, then clearly show how the available evidence led to suspicion. The reporting duty […]
When an existing client review uncovers an unexplained transaction, inconsistency, or gap in the supporting evidence, accountancy firms must decide whether standard enquiries can resolve the matter or whether it should be escalated as a suspicion. The outcome can affect work already underway, particularly when a filing or piece of advice is linked to the […]
Accountants must know how to respond when information gathered before accepting a client points to possible money laundering or terrorist financing. While routine onboarding questions can resolve an inconsistency, if the available facts support suspicion, the practice must stop the engagement from progressing and use its formal reporting process. The person who identifies the AML […]
When an accountant identifies information that may require a suspicious activity report (SAR), the practice must preserve a clear record of the concern and the money laundering reporting officer’s (MLRO) response. That information must remain separate from routine client papers so that staff, clients, and service providers do not discover the existence of the case […]
When an internal suspicious activity report (SAR) reaches the money laundering reporting office (MLRO), they become responsible for deciding how the practice should respond. This process includes managing any immediate risk to current engagements, and independently determining whether the information supports an external SAR or a separate defence against money laundering (DAML) request. Importantly, the […]
In a small accountancy practice, the MLRO role is significantly more important than an administrative appointment. It is the point at which internal concerns about possible money laundering are assessed and, where necessary, turned into an external report. The role needs someone with direct access to the client file and engagement context, as well as […]
While Suspicious Activity Reports (SARs) are a rare event for small accountancy firms, the difficulty lies in knowing when an unusual client matter has moved beyond a routine query. This judgment is fundamental because the wrong response can create real anti-money laundering (AML) compliance problems for the firm. Staff must know when to escalate a […]
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FCA supervision will bring tougher scrutiny, clearer evidence expectations, and less room for messy AML files. This report explains what is changing and what small firms should tighten now.
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| ✓ | What the FCA transition means for small accountancy firms in real terms |
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