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Treasury Approved CCAB Guidance

By Julia Penny

On the 7th March 2018 the CCAB issued the final HM Treasury approved version of the anti-money laundering guidance for the accountancy sector. Whilst there are a lot of changes due to a general tidying up, for example using the word country instead of jurisdiction, there are not many of more significance. However, some points are worth noting as follows:

Training and Relevant Employees

The definition of a relevant employee has been changed to specifically include partners. Previously, it appeared that, whilst common sense dictated that partners needed to know about all the Regulations and requirements, the strict interpretation of the requirements seemed only to apply to employees and not partners.

This means that both partners and staff will need to have training on the requirements of the money laundering and terrorist finance (MLTF) regime. Additionally that training must include data protection requirements and consideration should be given as to whether there is some sort of assessment of the level of knowledge and understanding the relevant employees have obtained.

Sole Practitioner

The dispensations for sole practitioners who have no employees have been brought together in Section 3.2, rather than being scattered through the document. A sole practitioner with no employees is not required to appoint an MLRO or senior management responsible for the Regulations. This makes sense of course, because of course the sole practitioner will have both of those responsibilities him or herself.

Additionally, sole practitioners with no employees need not implement regular independent reviews unless required by their AML supervisor. This dispensation seems a little strange to me, as it might be thought that someone in sole charge of a business could benefit from an independent review of their files, but perhaps this was felt too onerous in a business confined to just one individual. In practice though, it seems likely that a sole practitioner may still want to periodically assess their compliance with the Regulations and may therefore engage a third party to carry out such a review.

FCA Guidance on Who Is a PEP

The FCA issues useful guidance on who is or isn’t to be regarded as a Politically Exposed Person (PEP) and the final version of this guidance cross-refers the user to this, saying that it may be useful. This is a sensible inclusion, as there are often questions as to which types of people fall into the definition.

EDD for PEPs

The final version of the guidance includes more nuanced information on understanding the different levels of enhanced due diligence (EDD) required for a PEP. Although both UK and foreign PEPs are now caught by the definition, there is a clear understanding that certain PEPs are less risky than others. The guidance points out though, that even UK PEPs may be regarded as higher risk if, for instance, there is evidence of concern such as involvement in the expenses scandal or indications of acceptance of inducements or similar.

The final guidance also makes it clear that a family member of a PEP ceases to require EDD as soon as the PEP ceases to hold the relevant role, not 12 months after as is the case for the PEP themselves.

Risk Assessment and CDD

There is emphasis on the fact that risk assessments must not be done by using a “tick-box” approach, but must consider all the relevant risk factors and how they might interact.

Client identification for a company or LLP has a small clarification to indicate that any beneficial owner or individual who exercises control over management must be identified (and verified on a risk-sensitive basis). This means that whether you verify the identity of shareholders/directors or other beneficial owners will be a matter of consideration based on the risks in the circumstances.

There is also clarification that when seeing a passport or other document for identification purposes this should be recent, as well as valid.

Bank Statements Printed from the Internet

The final version of the guidance removes the prohibition on using bank statements printed from the internet as part of the CDD procedures. No doubt this is due to the dearth of statements sent by the bank in the post! However, the accountant is still required to consider the likely veracity of such information before deciding whether it is suitable to accept it.

Secondees and Outsourcing

The information on this has now been moved to an appendix, presumably to ease reading of the document for those not affected.

Our Money Laundering Manuals

The SWAT and Mercia manuals have already been updated for the draft CCAB money laundering guidance. As you can see from the above the changes required in respect of the final versions will not be extensive. However, minor changes to the manuals will be made to reflect the current position and these will be done by late Spring 2018.

In addition to the minor changes required where relevant, a new training module will be included. However, as previously noted, the overall training for all individuals is not substantially different under the new regime compared to the old one, so in the meantime you should still ensure all staff have had relevant money laundering training and been provided with update bulletins or articles to read about the changes, which are available either in your manual or on our websites.


With a new money laundering “super” regulator (OPBAS) being imposed on the sector, it is reasonable to suppose that an improvement in the application of the requirements is expected. QAD or other regulatory visits may well focus on these new requirements, but also the previous ones, which were not so different. To help you, SWAT and Mercia have a range of manuals and information. Key links are below, but do phone or email your usual contact if you have any further questions.  The SWAT telephone number is 0845 450 5555*.


March 2018 


This article is published with the understanding that SWAT UK Limited is not engaged in rendering legal or professional services. The material contained in this article neither purports, nor is intended to be, advice on any particular matter. This article is an aid and cannot be expected to replace professional judgment. SWAT UK accepts no responsibility or liability to any person in respect of anything done or omitted to be done by any such person in reliance, whether sole or partial, upon the whole or any part of the contents of this article.