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ICAEW Anti-Money Laundering Service

Taking the risk out of compliance

From as little as £99* per firm per year

You don't have to be an ICAEW member to join! This service is applicable to non-ICAEW members also.


Accountancy firms have had to comply with anti-money laundering legislation since 2004. During that time the requirements have changed several times and changes are set to continue with the 4th EU AML Directive due in the near future.

Although many firms have the required anti-money laundering (AML) policies and procedures in place, the level of compliance varies widely. Both ICAEW and SWAT UK regularly come across firms that have AML issues or a lack of understanding in the following areas:

  • the duty to report knowledge or suspicion;
  • the exemption from reporting in privileged circumstances;
  • customer due diligence and beneficial ownership;
  • avoiding tipping-off; and
  • carrying out adequate risk assessments

It’s vital to have the correct systems in place and to give staff regular AML updates and training to make sure your firm is complying with the latest regulations. ICAEW has partnered with SWAT UK to develop the ICAEW Anti-Money Laundering Service to raise firms’ awareness of their AML obligations and help them implement correct procedures.

ICAEW has 13,000 practising firms, as well as being a supervisory body responsible for ensuring AML compliance by its members. As such it has considerable insight into the AML compliance issues that firms encounter. SWAT UK is the largest independent provider of compliance and quality reviews in the UK and has an enviable reputation for providing AML compliance products and services. 

Our AML service will give your firm the guidance and practical tools you need to comply with the regulations. You’ll also have online access to a range of practical documentation, helpsheets and training, tailored specifically to the size of your firm and the profile of your clients.

Although the Anti Money Laundering Service has been designed in conjunction with ICAEW, it is suitable for accountancy practices affiliated to any professional accountancy body.

Choose the right AML system based on your client profile

The ICAEW AML Service comprises three web-based systems that are tailored to different types of firms and their clients:

  • Basic System - Aimed at sole practitioners with no staff or subcontractors (or just one or two) with a limited variety of clients, all of whom operate purely within the UK. Find out more >
  • Standard System - Aimed at firms with staff dealing with a more varied client portfolio, all of whom operate purely within the UK. Find out more >
  • Complete System - Supporting firms of any size who have UK or overseas clients, or UK clients with overseas connections. Find out more >

The three systems are intended to cater for the compliance needs of all small and mid-tier accountancy firms.

Refer to the table below for an overview of each system, or see our flow diagram (click here) to identify which system best suits your requirements.

 

Online specialist anti money laundering training

In addition to our three web-based systems, the Service also provides specialist AML training and systems covering the areas of tax consultancy, corporate finance, litigation support and insolvency. Click here to find out more >

Compare the systems

   

Basic System

Standard System

Complete System

Suitable for
Sole practitioners with no staff or subcontractors (or just one or two) with a limited variety of clients, all of whom operate purely within the UK. Firms with staff dealing with a more varied client portfolio, all of whom operate purely within the UK. Firms of any size who have UK or overseas clients, or UK clients with overseas connections.
 

£99 per annum* 

£199 per annum* 

£549 per annum* 

   


 

Geographical limitations

     
UK-based clients with UK customers who operate purely in the UK Covered Covered Covered
Overseas clients or UK clients with overseas connections (customers, suppliers, branches, investors etc) Covered

Staffing limitations

     
Number of staff / subcontractors Maximum of 2  No limit  No limit 

Client types covered (with relevant customer due diligence forms)

     

Sole-traders / Individuals

UK only UK only Full
Professional firms subject to ML Regulations
UK only Full
Other partnerships and unincorporated businesses
UK only UK only Full
Unlisted limited companies
UK only UK only Full
Listed companies
Full
Charities
UK only UK only Full
Church bodies and places of worship
UK only Full
Clubs and societies
UK only Full
FSA / FCA(1) authorised entities
UK only Full
Pension schemes
Full
Trusts or foundations UK only Full
UK public sector bodies, government departments, councils and other local authorities
Full
Non-UK public sector bodies, government departments, councils and other local authorities
Full

Other documentation included


   

Example AML policies and procedures

 

Simplified version UK only Full
Client risk assessment flowchart
 Simplified version UK only
Client risk assessment flowchart - for individuals
Full
Client risk assessment flowchart - for entities
Full
KYC forms with annual review - for individuals
UK only UK only Full
KYC forms with annual review - for entities
UK only UK only Full
Annual declaration form by staff
Full Full
Annual compliance review form
 Simplified version More detailed Full
Suspicious Activity Report
Full Full Full

Help Sheets

     
Policies and procedures UK only Full
Customer due diligence
Summary
Customer due diligence - introduction Full Full
Customer due diligence – entities
UK only Full
Customer due diligence – directors, trustees etc
Full Full
Customer due diligence – beneficial owners
UK only Full
Customer due diligence – simplified due diligence
Full
Customer due diligence – electronic verification
Full
Customer due diligence – PEPs and sanctions checks
Full
Customer due diligence – reliance on third parties
Full
Customer due diligence – certified copies
UK only UK only Full
Ongoing monitoring
UK only UK only Full
Duty to report
UK only UK only Full
Obtaining consent
Routine work only Routine work only Full
Exemption from reporting in privileged circumstances
Full Full Full
Tipping off
UK only UK only Full
AML Training
Routine work only Full
Record keeping
Full Full Full
Equivalent jurisdictions for money laundering purposes
Full
High risk jurisdictions for money laundering and anti-terrorist financing
Full

Training

     
Online introductory training
Access for single person only. Additional persons are charged separately Unlimited access  Unlimited access 
Access to SWAT UK's Bribery Act 2010 online course Access for single person only. Additional persons are charged separately   Unlimited access   Unlimited access 
Live annual anti-money laundering update webinar
May be purchased separately May be purchased separately Unlimited access 
Online recording of annual anti-money laundering update webinar
May be purchased separately
May be purchased separately
Unlimited access
Online recording of specialist anti-money laundering training on:
  • tax consultancy
  • corporate finance
  • litigation support 
  • insolvency
May be purchased separately May be purchased separately May be purchased separately
Annual newswire of key changes during the year
Included
Six-monthly summary newswire of key changes and topical information
Included Included
Monthly newswire of key changes and topical information
Included
   

(1) On 1 April 2013 the FSA (Financial Services Authority) became the FCA (Financial Conduct Authority)

*Prices exclude VAT and are payable in full at the start of your subscription period. Prices are valid until 31 December 2017. The ICAEW Anti-Money Laundering Service is a 12 month online subscription package. Prices are per firm per year and entitle your firm to any updates which are made to your Anti-Money Laundering System throughout the course of your 12 month subscription. Subscribers will be notified when any documentation has been added or updated within your Anti-Money Laundering System.

< Back to AML Systems Overview

ICAEW Anti-Money Laundering Service - Basic System

Price: £99 per annum*

Who is the Basic System suitable for?

The Basic System is aimed at sole practitioners with no staff or subcontractors (or just one or two) with a limited variety of clients, all of whom operate purely within the UK.

Confirm this is the correct version for your business using our "confirmation of suitability" checklist > 

Basic System - contents

Documentation and helpsheets

  • Example basic AML policies and procedures
  • Client risk assessment flowchart and forms 
  • KYC form for individuals incorporating section to evidence annual review
  • KYC form for businesses incorporating section to evidence annual review
  • Simple to use customer due diligence forms giving the identification options for the follow UK client types:
    • Individuals / sole traders
    • Partnerships and unincorporated businesses
    • Limited companies (unlisted)
    • Charities
  • Series of short help sheets:
    • Customer due diligence
    • Customer due diligence – certified copies
    • On-going monitoring
    • Duty to report
    • Obtaining consent
    • Exemption from reporting in privileged circumstances
    • Tipping off
    • Record keeping
  • Annual compliance review form 
  • Suspicious Activity Report

Training included

Additional training available (additional cost as required)

 

You may also be interested in:

> ICAEW AML Service - Standard System

> ICAEW AML Service - Complete System

> ICAEW AML Service - Compare the systems

> Which AML system is right for me?

> Online specialist anti money laundering training

 

*Prices exclude VAT and are payable in full at the start of your subscription period. Price is valid until 31 December 2017. The ICAEW Anti-Money Laundering Service is a 12 month online subscription package. Prices are per firm per year and entitle your firm to any updates which are made to your Anti-Money Laundering System throughout the course of your 12 month subscription. Subscribers will be notified when any documentation has been added or updated within your Anti-Money Laundering System.

Please note - we will need to process your order before you can access the client area, which may take up to 48 hours. As soon as your order has been processed, we will send you an email notification, giving you instructions on how to access the client area online. If you haven't received this within 48 hours of your order, please call us on 0845 450 5555.

< Back to AML Systems Overview

ICAEW Anti-Money Laundering Service - Standard System

Price: £199 per annum*

Who is the Standard System suitable for?

The Standard System is aimed at firms with staff dealing with a more varied client portfolio, all of whom operate purely within the UK. The Standard System is not designed for firms whose clients have overseas activities (for this level of support, please refer to the Complete System).

Confirm this is the correct version for your business using our "confirmation of suitability" checklist > 

Standard System - contents

Documentation and helpsheets

  • Example AML policies and procedures
  • Client risk assessment flowchart and forms
  • KYC form for individuals incorporating section to evidence annual review
  • KYC form for businesses incorporating section to evidence annual review
  • Simple to use customer due diligence forms giving the identification options for the follow UK client types:
      -  Individuals / sole traders
      -  Professional partnerships
      -  Other partnerships and unincorporated businesses
      -  Limited companies (unlisted)
      -  FSA / FCA(1) authorised businesses
      -  Charities
      -  Clubs or societies
      -  Churches or places of worship
      -  Trusts and foundations
  • Annual declaration form by staff
  • Annual compliance review form
  • Suspicious Activity Report
  • Series of short help sheets:
      -  Policies and procedures
      -  Customer due diligence – introduction
      -  Customer due diligence – entities
      -  Customer due diligence – directors, trustees etc.
      -  Customer due diligence – beneficial owners
      -  Customer due diligence – certified copies
      -  On-going monitoring
      -  Duty to report
      -  Obtaining consent
      -  Exemption from reporting in privileged circumstances
      -  Tipping off
      -  AML trainingRecord keeping

Training included

 

Additional training available (additional cost as required)


You may also be interested in:

> ICAEW AML Service - Complete System

> ICAEW AML Service - Compare the systems

> Which AML system is right for me?

> Online specialist anti money laundering training

 

*Prices exclude VAT and are payable in full at the start of your subscription period. Price is valid until 31 December 2017. The ICAEW Anti-Money Laundering Service is a 12 month online subscription package. Prices are per firm per year and entitle your firm to any updates which are made to your Anti-Money Laundering System throughout the course of your 12 month subscription. Subscribers will be notified when any documentation has been added or updated within your Anti-Money Laundering System.

Please note - we will need to process your order before you can access the client area, which may take up to 48 hours. As soon as your order has been processed, we will send you an email notification, giving you instructions on how to access the client area online. If you haven't received this within 48 hours of your order, please call us on 0845 450 5555.

(1) On 1 April 2013 the FSA (Financial Services Authority) became the FCA (Financial Conduct Authority)

< Back to AML Systems Overview

ICAEW Anti-Money Laundering Service - Complete System

Price: £549 per annum*

Who is the Complete System suitable for?

The Complete System has been created to support firms of any size who have UK or overseas clients, or UK clients with overseas connections.

Complete System - contents

Documentation and helpsheets

  • Example policies and procedures
  • Client risk assessment flowchart and risk assessment form for individuals
  • Client risk assessment flowchart and risk assessment form for entities
  • KYC form for individuals incorporating section to evidence annual review
  • KYC form for businesses incorporating section to evidence annual review
  • Simple to use customer due diligence forms giving the identification options for the follow client types:
      -  Individuals / sole traders

      -  Professional firms subject to ML Regulations

      -  Other partnerships and unincorporated businesses
      -  Limited companies (unlisted)
      -  Limited companies (listed)
      -  FSA / FCA(1) authorised businesses
      -  Charities
      -  Church bodies and places of worship
      -  Clubs and societies
      -  Trusts and foundations
      -  Pension schemes
      -  UK Government departments, councils and other local authorities (including state supported schools, colleges, universities and NHS trusts)
      -  Non-UK pub
    lic sector bodies, government departments, councils and other local authorities

  • Annual declaration form by staff
  • Annual compliance review form
  • Series of short help sheets:
      -  Policies and procedures

      -  Customer due diligence – introduction

      -  Customer due diligence – entities

      -  Customer due diligence – directors, trustees etc.

      -  Customer due diligence – beneficial owners

      -  Customer due diligence – simplified due diligence

      -  Customer due diligence – electronic verification

      -  Customer due diligence – PEPs and sanctions
      -  Customer due diligence – reliance on third parties

      -  Customer due diligence – certified copies

      -  On-going monitoring

      -  Duty to report

      -  Obtaining consent

      -  Exemption from reporting in privileged circumstances

      -  Tipping off

      -  Anti-money laundering training

      -  Record keeping

      -  Equivalent jurisdictions for money laundering purposes

      -  High risk jurisdictions for money laundering and anti-terrorist financing

Training included

You may also be interested in:

> ICAEW AML Service - Compare the systems

> Which AML system is right for me?

> Online specialist anti money laundering training

 

*Prices exclude VAT and are payable in full at the start of your subscription period. Price is valid until 31 December 2017. The ICAEW Anti-Money Laundering Service is a 12 month online subscription package. Prices are per firm per year and entitle your firm to any updates which are made to your Anti-Money Laundering System throughout the course of your 12 month subscription. Subscribers will be notified when any documentation has been added or updated within your Anti-Money Laundering System.

Please note - we will need to process your order before you can access the client area, which may take up to 48 hours. As soon as your order has been processed, we will send you an email notification, giving you instructions on how to access the client area online. If you haven't received this within 48 hours of your order, please call us on 0845 450 5555.

(1) On 1 April 2013 the FSA (Financial Services Authority) became the FCA (Financial Conduct Authority)


< Back to AML Systems Overview

Specialist Training

These live webinars range from 30 to 60 minutes, depending on the complexity of the subject. They will all be recorded and available to watch online after the live event.

Annual Anti Money Laundering Update

This course will include:

  • Any changes / amendments to the Money Laundering Regulations 
  • Any updates to the guidance or any AML related pronouncements by the main regulatory bodies
  • Any recent case law having an impact on AML issues
  • Updated information about countries with equivalent and those with weak AML regimes
  • SWAT UK guidance on the common problems experienced by firms when implementing AML policies and procedures
  • A selection of real (anonymous) queries from firms in practice and the answer provided by SWAT UK. These questions may relate to obtaining identification; the duty to report; the reporting exemption in privileged circumstances; tipping off; and other issues.

 

You may also be interested in:

> ICAEW AML Service - Basic System

> ICAEW AML Service - Standard System

> ICAEW AML Service - Complete System

> ICAEW AML Service - Compare the systems

> Which AML system is right for me?

 

Which AML System Do You Require?

This flow diagram will help you identify the Anti Money Laundering Service that best fits your requirements, firm size and client profile.

FAQs

I am a sole practitioner and only have one overseas client. Can I still use the basic or the standard system?

Unfortunately the answer is no. In arriving at the basic system we have had to make assumptions about the typical client base for a sole practitioner with no staff, or just one or two staff.

If you deal with any overseas client s at all then a range of other issues come into force which can affect the risk profile of the client, the firm’s policies and procedures and the help sheets that you need. For example you will need to consider:

  • The latest FATF list of high risk jurisdictions
  • Countries with equivalent ML regulations
  • Politically exposed persons
  • Countries whose trusts, companies etc offer anonymity
  • Overseas activities in terms of your duty to report

By the time you update the risk assessment, documents, policies and procedures and help sheets for these issues you have effectively got the complete system.

I am a sole practitioner with three staff. Since this is not significantly different from one or two staff can I use the basic system?

The basic system is really aimed at sole practitioners on their own. However, we have extended it to allow for one or maybe two staff / subcontractors at most.

As soon as you allow for any staff you need formal policies and procedures. The basic system has very brief / simple policies and procedures. Where you have the more staff you need more detailed policies and procedures which need to include 

  • Initial AML training
  • ongoing AML training on recognising and dealing with suspicious transactions
  • formal reporting procedures
  • guidance on tipping off / prejudicing investigations
  • annual declarations of understanding

The basic system does not include these items and so is not designed for more than one or two staff at most. So, even with just three staff you should go for the standard system.

I am a sole practitioner with three staff. Although there are three they only equate to just over one full time person. Can I use the basic system?

As indicated in the question above more formal procedures are required where you have more than one or two staff. 

It is not the full time equivalent that is relevant. Instead it is the number of individuals. 

The more individuals you have the more scope there is for misunderstanding, confusion and inconsistent approaches, hence the need for more formalised training and procedures.

I work on my own with no staff. Whilst most of my clients fall within those covered by the basic system. However, I do have a church, an FSA authorised client and several trusts. Can I just buy the basic system and pay a bit extra for the additional due diligence forms?

Unfortunately no. The main issue here is the practical issue of delivering the system. Each system is set up on a separate section of the SWAT UK website. Once you have access to part of the system you are automatically allowed access to the whole system. You cannot pick and mix between the systems.

How will I know when you have changed a form or other document?

The system has a tab on the web page that will list any changes to documents and when they were changed. We will also refer to changes in the email newswire that goes with the system.

If I subscribe to the basic or standard system can I still attend any of the specialist training courses on AML?

Yes, all specialist AML training can be booked separately. Indeed, none of it is included in any of the systems.

What will I need to be able to watch the webinar or webinar recording?

Your starting point is a computer with a sound card and speakers or headphones.

For the live webinar you will need to download the free WebEx player, which is the system that we use for all our webinars. You can do this by clicking on the link in the joining instructions, but we recommend that you do this at least half an hour before the start of the webinar in case you have any difficulties and need some help.

For the recordings you will need to have Microsoft Silverlight installed. This is a free Microsoft product for viewing movies. Again, your joining instructions will explain this.

I am using the basic system and registered to attend the recording of the annual AML update webinar. I only have one member of staff. Can he watch the recording as well?

Yes, but our terms and conditions mean that you need to book him onto the recording and pay for him, even if he is watching it at the same time as you.

You pay the full price for the first delegate booked on the recording, but get a 50% discount on the second and any other delegates booked onto the system. The website booking automatically applies this 50% discount for someone from the same firm booking on the same webinar instance.

The same approach to pricing applies to the live webinar, with the first delegate paying full price and any subsequent delegates from the same firm paying half price. 

However, we treat the live and the recorded version of the webinar as separate events, so if you watched the live event and your staff member watched the recording you would both be charged the full price.

If I have a technical question on an AML issue can I ring you to discuss it?

The ICAEW has a free and confidential technical help line that members can use: 01908 248 250.

SWAT UK also provides technical advice on AML issues, although this will result in a separate invoice, based on 15 minute units charged separately. You will receive an email from SWAT UK confirming the question you asked and the advice provided by SWAT UK.