VIP Video Library – Session 7

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The Irish Accounting & Tax Summit

Session 7 - Anti-Money Laundering for Accountants in 2020

Session 7 - Presentation

Session Transcript

This transcript was created using AI and may contain some mistakes.

Hello and welcome everyone to the Irish Accounting and Tax Summit 2020. And I’d like to welcome you all to our, for all our virtual attendees today. And I hope today’s web webinar is beneficial to all we’re already in week two of the RHD counting, uh, the Kevin on tax almost at on day four of age. And today we’ll be covering session seven.

I have seven and 87 is Mike’s AML webinar. And H is John’s tax appeals in 2020. And today, as I said, we’re covering anti money laundering for accountants. And I’m joined by Michael Holland who will present today’s topic. Yeah, today’s a, it’s a one hour session from 11 to 12. Mmm. Well, I worked a lot of works,

a lot of myself and practice support hour where the parent has helped firms on a day to day basis for their annual compliance reviews. Oh, thought of yours. It has training pre and post myalgic and many other areas. And prior to joining YPO, I applied to join the army for help. I’m like, am I sat LA Mike, like myself spent a number of years with their charge accountants as a reviewer.

And part of his remiss, it was carried an anti money laundering reviews in addition to his normal day to day stuff like audit or knowledge. Yup. Before joining M before I stated in chargers and like I’ll spend time to practice. So today in fairness, he brings a very beneficial insight into what’s required in terms of AML compliance, particularly Indian, certain times that we have ourselves in COVID-19 and the lockdown.

Well, we’re trying to downloads, Mike has provided some downloads for today’s session and I, John has put up the link into the common, the common box and honestly take time to doubt a day to access these downloads because they do provide some useful guidance. Yeah. Okay. And once you have the, Mike’s going to go through, go, go,

go through the pocket in detail. So in terms of questions, and obviously we value your questions and it makes the session a bit more, a bit more free flowing. So we appreciate, I appreciate your questions. There’s two ways of doing this. Yeah. One in the chat box and you can send the queries to all panelists or send them directly to myself,

collarbones and all, and then feed them one to Mike or in the Q and a box. Yeah. And then they will be able to answer them all. We’ll try. Amen. It’s a big topic, but we’ll try and get you as many questions as we can drag throughout the session and are other juries or, or, or at the end.

And we have allowed some time for general, Q and a, so we should be able to cover them all for the, all off the reading that optimized for today’s session. Well covered AML. So yeah, you know, it’s a, it’s a, it’s an ongoing, it’s an ongoing compliance and compliance area. And I think there’s a lot more focus on Amazon now,

you know, in general from the, from the, from the Institute and optimal or so maybe because of, because of COVID-19. Yeah, absolutely. Yeah. And actually, let me just start by just sharing my screen here. Um, Hopefully, hopefully that’s okay. Yeah. So it is, I mean, it’s like the big thing the last couple of months obviously has been,

uh, well, first of all, institutes have been far more focused on AML and I think you’ll probably appreciate when, when you enable and tell student reviews as reviewers, it was probably a bit more light touch than the current than the currently is. And I suppose the reason for that is that certainly I know a charter does not have a more focused it’s an AML only visit as opposed to particular visits we would have done,

which would have been an audit visits at your while you’re there you’ll have a look at AML as well. And it was, it was, I don’t want to say light touch, but it certainly wasn’t as stringent as the lens that reviewers are going to now. So I suppose that that’s one area and that’s topical at the moment. And obviously the other one is,

is the whole interaction with, with, uh, the pandemic at the woman and just, uh, how we can navigate through the problems that, that poses. So just to, uh, just five topics we’re going to be covering today. So we have the first topic we’re going to be talking about is just the uptick of the legislation. What is money laundering?

We’re going to be discussing the role of the money laundering reporting officer. So I’m sure there’s a couple of, of money laundering reporting officers in the, in the audience today. So first of all, congratulations on the appointment and I’m sure you were delighted with the, with the appointments, but we’re just going to discuss, okay, well, what’s involved with being a money laundering reporting officer,

and why, why, why is it a position of such significance topic three, then we’ll be covering risk assessments, business risk assessments, and also, um, client risk assessments. So there are obviously two separate things and customer due diligence, topic four, we’re going to be talking about reporting procedures and, uh, professional privilege exemption. And then topic five,

we’re going to finish with an update on COVID-19 and any recent legislative updates, including the forthcoming, um, AML directors that we hopefully will be on that hopefully, but that are likely going to be implemented in 2020. So just to go through quickly, there’s obviously a, there’s obviously a notes pack as well. Uh, we’re not going to go through everything in the notes pack,

but it does have some useless supporting documentation. So we have, we have a sample AML from business risk assessment, which we’ll be going through. That’s quite a new development that came in would have it’s a requirement since the 2018 legislations. We’ll go through that. We also have the, uh, the amended, uh, criminal justice, 2010 act. So the copy of the legislation,

uh, as amended by the 2018 act, and then we have the CCA BI guidance, which is very useful for technical release, this that everyone should, should use, uh, when, when addressing not particularly difficult for my I’m anti money laundering issues. So it would be kind of would be going in and out with them as we go on. So as regards to the applicable legislation,

so, uh, criminal justice acts of 94, 2003, I suppose, is where, where AML kind of became its significance for accountants, particularly in 2003, when we, when accountants were identified as designated persons. And obviously then that’s where our requirements to, uh, to deal with money laundering came from the, the big piece of legislation obviously is the 2010 act,

the criminal justice money laundering and terrorist financing act. And, you know, that expanded on the original procedures. It also adopted what we know, look at it as a risk based approach to anti money laundering, and then we’ve had subsequent amendments. So we’ve the 2013 amendments that’s just strengthened enforcement and introduce this whole concept of a professional privilege reporting. And then 2018 act with implemented the provisions of the fourth EU directive as regards to legislation would be discussing it towards the end.

Um, you know, there are, we’re talking about the fourth EU directive, the 50 new directive we’re currently due to implement. We were late implementing it. So I think it was due for implementation in January, but obviously things more important things came through the forest since January and it hasn’t been done zone. Yes. And also there’s the thoughts of the 60th director of Tessa that is used to be implemented?

I think towards the, I think the deadline is the end of 2020. I wouldn’t hold our rights for that. If the fifth directive isn’t implemented yet. So as regards guidance material, the, the, the, the previous light was legislative stuff. This is, um, what guidance materials we can use. So this is the first one. And again,

that’s an important one. It’s the CCA BI, uh, technical release of, of 2019. So that, that’s, that’s an important one because although it’s a guidance document, it’s actually a lot more than a guidance documents. And that’s effectively the standard that the recognized accounting bodies wants to hold firms to when they come out and view their files. And there’s a particular provision in the,

in the, uh, the guidance document. I think it’s page, page one, eight, four, uh, it’s actually that, by the way, the numbers, yeah.<inaudible> system, when I’m referring to page numbers, it’s the pay, it’s the number in the bottom corner? I think that the PDF number is slightly different. This is the CCA guidance.

And, uh, this, this paragraph here is important. If a supervisory authority is called upon to judge, whether an accountancy firms compliance with its general ethical or regulatory requirements, this is likely to be influenced by whether or not the firm has applied the provisions of this guidance. So as a result, it’s more than just a guidance document. It’s the standards that the,

that the recognized accounting bodies expense to all hold you to, uh, on top of that firms are required to have their own policies and procedures. You know, anyone with access to the arc would like to have taken the template that’s up there and then tailored it for our, uh, for your own particular circumstances. And as well as that said, just AML guidance material on the,

on the accounts, this resource center as well. So what is that? What is money laundering? So it’s defined as all forms of handling possessing, the proceeds of criminal conduct, where the person knows, and I believe switch proceeds is or represents the proceeds of criminal conduct and the proceeds of criminal conduct means any property that’s derived from are obtained through criminal conduct,

whether directly or indirectly, or in whole, or in parent, obviously that’s quite a legal definition. I mean, the most likely situation that accountant is going to encounter money laundering, tax evasion, you know, non declaring of income fraud, things like that. But that’s the, I suppose, the legislative definition, it’s important to note too, that said that money laundering it doesn’t,

it doesn’t just involve cash. It can involve security property, carers, boats, for whatever intangible property, things like that. So just obviously to be aware that it’s not necessarily just money, although it’s usually, you know, it often is, um, for a matter to be money laundering to must not only be criminal conduct, but also the proceeds of criminal conduct.

So again, if you identify criminal conduct, but there’s no proceeds, you know, the there’s no money laundering offense because almost there must be four seats in order for it to be a money laundering offense. Uh, it extends to the facilitation do use or possession of proceeds. So again, it’s not just, you know, if your facility, if there’s art you’re found to be facilitating is that’s covered by money laundering as well.

And the punishment there is very strong, um, convictions or anonymous and fine, not to 14 years in prison. And I suppose that’s purely dealing with the criminality side of it. So, you know, some, someone convicted them on money laundering offenses, I suppose, the criminal justice act. If it’s legislation that’s strong and it’s legislation that’s used quite often in the area of criminality.

And I mean, I think in the paper a few days ago, I saw that someone charged with 50 counts with empty money laundering offenses under the criminal justice act. So it is legislation that’s very strong and it is used. So what is money laundering? I suppose it can, if the activity of money laundering can be white and compensating, so it can be a single act.

So, I mean, a single transaction or a single single act, or it can be a bit more complex. I mean, the more sophisticated ones, you know, and said, instead of, you know, it’s involved in one single transaction, it might involve your money going from here to here, to here into, into a secret of jurisdiction under that jurisdiction.

And it can be layered. So just be aware of this because there’s probably no one set form that money laundering can take, but it can be, you can take a number of forms. And I suppose the more sophisticated ones there tends to be layers of transactions. Um, so as regards the money laundering reporting officer, um, the legislation States that firms can appoint him when you launder money laundering officer,

if they decided to prop it as part of the procedures that they adopt, um, you know, it’s, it says, it says you can. And what I mean, I think it’s fair to say Columbus, that she, you know, I go a bit stronger than cannon and I mean, you would have to, I mean, if you don’t apply,

if you don’t have to point the money laundering reporting officer, then the responsibility effectively falls with all of the individual staff members and you kind of lose you lose control effectively, if you don’t. Yeah, I think so. I think, I think that’s like, that’s the, the main trust for they’re exactly like in terms of, you know, you don’t want an affirm,

you don’t want every staff member making, making make an external report. What do you nearly two to, to, to do ever? And so I think, I think that’s the point that lights covers off on life while you don’t have to am, or you don’t have to, you know, get up close Bush. And if you don’t then need individual individual AMS staff members are obliged and then also competent are the other roles.

I’m sure you’re going to go on to, in terms of compliance and various things like that. Gosh, that falls under the remit of the MRO. If there was a lemon row there, I think it’s the firm it’s alpha or the owners of the firm or whatever we call them become liable for any M Brandy for an age noncompliance. Yeah, absolutely.

Ideally you want this, you want the autonomy and you want, you want to have the control and you want to have, you know, a person with a safe pair of hands that, you know, that, you know, can handle the rules, but it should be. I mean, I think there’s, there certainly should be a money laundering reporting officer appointed.

So then I suppose that begs the question, who should the money laundering reporting officer be? Um, I mean, keeping that there needs to be someone at senior level. I mean, it’s not a job you give to the fourth year trainee, do you extend the door? Or, you know, someone, someone, maybe a junior level, it has to be someone at a senior level because,

you know, I mean, when things get serious, you need someone who, who who’s able to see, they control the situation. And, you know, even if you have, if you have an unfortunate circumstance where the guards are, revenue arrived on the, on the back of something, whether it’s the money laundering reporting officer that they want to interview,

they won’t necessarily want to interview the partners. That you’d be the money laundering officer that they want to interview. So it should be someone that’s asked an appropriately senior level. It also should be someone who knows the clients that business and America, I’m sure my daughter and I have the room here. No worries. It will be somebody that knows the clients,

the business, and they’re under American sector. Yeah. I think, I think that’s an important bit there as well, because that ties into what, you know, what you’re going to come onto later on a bed like the federal wide risk assessment. So that’s one of the, that, that’s one of the key, the key, um, um,

new additions, um, from the act, what that’s a, on an annual basis, it goes through all of this. What you’ve seen you spoke spoken about. So if this, if the person, the MLRO is meant to do this, if they don’t know if they’re a junior, they don’t know all the type of clients to have, but aren’t privy to,

um, to any on your clients that are affirmed may have. So maybe, you know, they kind of group leaders. Yeah. Yeah. And, and, you know, if you’re not at that level, how can you complete the business risk assessments? You do need to know, you need to need to know all those, uh, all your finance,

the businesses that the, in a big one too, you need to have the confidence to, to make reports. Um, you know, it’s, uh, you know, the, the, there will be an internal, assuming you’ve replayed your procedures correctly, you’ll have an internal reporting function whereby let’s say, I am the staff member and you were the money laundering reporting,

officer icy, something that I looked think, look suspicious. I reported to you, or you need to have the confidence to look at my reports, say, okay, does that carry weight? If it does well, we need to make an external report and need to be able to deal with external organizations. So again, that’s obviously dealing with the guards dealing with,

uh, anyone else should the unfortunate circumstances arise, where you have to have to deal with them. You need to be obviously competence to deal with those bodies. Um, and, and do you need to ensure that management’s properly addressed the money laundering requirements? So obviously you need to have procedures in place. You need to ensure that you’re at your risk assessments are computers and et cetera.

So the role of the money laundering reporting officer, so it’s a fairly wide encompassing role of that that falls under, under shoulders. So we design it first of all, design and implement internally in a systems, obviously the easiest way to do that. Anyone who’s a member of the arc will have access to the, the procedures templates that can obviously be tailored appropriately.

And, and, and, um, I use once it’s, once it’s tailored to the firm’s needs the, uh, the role. So as well as that, we discussed already receive internal reports of suspicions from other staff members. Once you’ve received those reports, consider the facts and circumstances, and then decide whether or not to make an external report. I suppose,

it’s, uh, you know, usually when an internal suspicion is raised or less, it’s very hard to get to maybe an internal internal report and then consider that there’s no external reports required, you know, but if you are required to consider the facts and circumstances to see well, is an external report actually requires, uh, another role is that you need to ensure that staff have obtained appropriate training to be aware of that suspicious transactions.

You know, and that’s quite important to know from the day a staff member enters the doors. They should have some form of I’ll be in much painting here yet as their, as their adoption, because that’s what that’s, what’s, what’s required of the legislation and particularly reviewers. That’s what, that’s one of the areas that they’re, they’re honing in on lately,

just to, uh, just to see, okay, well, our staff trains, you know, how often do they train his trainings on and off on an ongoing basis? So even with when the legislation, can you just, do you have training to take into account recent legislative changes so that that’s obviously falls on the shoulders of the MLR altar to arrange that again,

act as a liaison point of the guarantees and the revenue commissioners, if that situation arises and it maintained the firm’s red cards in relation to any reported cases. So if you have any internal reports, any external reports that you’re required to, we’re required to retain those. Um, that’s mainly for regulatory bodies, as far as I’m aware of the regulatory bodies for them to launch,

tend to look as internal or external reports as part of the, as part of the monitoring process. Yeah, no, I think, I think, I think you’re right. I think what they’re, what they do look at is they do look at the procedures that are in place there that they have in there. And I think they do Colet cuts statistics.

So they’ll probably ask you for the number of various reports they have with it. I think they have a and onward report requirement, both Because they will come into your pores, hot bean made internally or externally. So I think, You know, I don’t, I think I, well, from my experience, the reason why they don’t want to go into review and review and report reports is They don’t want it to be suddenly tied into our report required because they,

the sea salt that maybe should have been reported or not like, you know, yeah. I think it was part of this report and goals. It’s more about your, your knowledge and your familiarity with the reporting system, as opposed to, well, you issued two external reports. Can we see both of them that, that don’t tend to go down that route,

but they do want to make sure that you’re aware of, well, what is a suspicious transaction reporting system and, you know, are you familiar with your requirements? And that’s the kind of route that they tend to go down there? Couple of questions I have to have come in, just so at the moment. And if you’ve got an MLO, I’m not sure where this question is coming from,

but if you have an MLRO, when a director reports direct revenue, I think obviously when I was a director of a, of a client, I think we probably cover that on the report on the report Requirements. And I’m not fully sure. We might need a bit, bit of clarification on that query. I’m not fully sure what’s what, what,

what, what that is. I actually, I got a question from Barry here is how often does trading have to happen for staff and what structure should it take? Um, I suppose how often does it have to happen? And I can’t remember the exact legislative definition, but it should be with sufficient regularity to ensure that you’re, you’re, you’re kept up to date.

And certainly when those legislative updates, certainly, uh, when staff members come into the door where the ship, some kind of, some kind of training for those. So that’s actually at each point, yep. Every staff member is XP up to date with the current legislation. Yeah. And like, you know, we’d be like, we’d obviously we’d be advising kind of annual I’m regular.

I think, I think it’s regular training. So I knew what a regular training in terms of even, even, even if there hasn’t been any, any, any, any new staff coming in. So there’d be no training there. Or if there’d be no updates legislation, you know, it’s no harm in having refresher every year on one off a 90 million order on your records,

because it is very easy to slip back into old dam, old, old, old, old habits as you go along. Yeah, absolutely. Um, the second last point there, just advising on how to proceed with work once or once a report has been made in order to avoid tipping off tipping off obviously is a big, it’s a big normal,

as far as AMS is concerned. And there has to be procedures in there. And, you know, a big thing for a money laundering reporting officer will be to sure, let’s say if I made a report to you, I’m the employee and you’re the money laundering reporting officer. If that happens, that’s, it’s a closed, it’s a closed communication channel that the only person who knew was an internal report that’s being made is,

is myself and yourself. I’m the only person that knows an external report that they made is you and the Garretts are, or whoever. And I suppose that that’s kind of what should be. You should be required. The money laundering reporting officer that there’s, you know, it’s things like that, or don’t confidentially that we’re not going on our tea break and then discussing those,

just discussing it after all, what, by the way, I report to this guy to the, to the money laundering reporting officer, it should be it’s the entire integrity of that reporting system is based on the fact that it’s a closed a closed communication channel, as well as that carry out to annual complaints reviews. So there should be a compliance review carried out for,

for AML. Um, I suppose there’s a number of ways you can do that. Obviously it’s a service that we carry out, uh, anyone who has the access to the arc, they will have, I think, in an appendix to the AML procedures, there’s a 10 page manual components review, if you want to do that internally. Um, but that,

that should be carried out annually. So what do you need to have? And I suppose this, this slide is quite important because if you have effectively everything on this slide, you know, you’re, you’re a long way you’re own way towards being covert from an AML point of view. So you should have documented procedures, you know, again, get the,

get the procedures, uh, get, get, get your templates and tailored accordingly. Um, one thing to point out there and you would’ve seen it too, when you were reviewer column, um, you know, a copy of the legislation and a copy of the CCA BI guidance at that that’s not procedures. Your procedures is a document that you own.

It’s a document that you tailor and it’s documented about, well, how do we apply the legislation to, to the firm? And that would be quite a common when maybe not in recent times, maybe in the area, these are a couple of years ago, that would have been a common enough point that would have been raised. Yeah, yeah. Very much so.

Yeah. At first, first we’ll take, once they was, have a copy of the legislation and most have the CCA at their procedures, which are dead. Like, you know, every farm is different. You could, you know, could we sell a partition and you could be with no staff focuses, you would admit with multiple load staff, you know,

multi partner from big firms, small firms, you know, the, the, the, the, the, the procedures and, you know, you need to have those type, those tailored procedures. And they need to be able to be given to staff members who could read and understand what the office procedures are, and then they could make reference to the legislation where it required,

or any other guidance when required. I think that’s a good, like, that is a key point. And that’s where firms would have been dinged on a right. Or, or, or brought up and, you know, Jared. Yeah. And I suppose at one point did that to that as well, is that your procedures should be updated regularly.

So windows legislative updates. So, you know, when, when the fifth and sixth AML directors come in, you know, they should be able to face or for any, any changes that are required by the light, the subsequent legislation. So risk assessments, both for the firm and the clients. So that’s actually two points there. So we’re required to do a business risk assessment,

which is what we’ll be discussing in a couple of, in a minute or two. And you’re also required to do a risk assessment for your clients to determine whether, you know, are they high, medium, low risk standard, enhanced due diligence are, are, are whatever that you’re required to have customer due diligence for all your clients. And again,

that’s, that’s where most of the work from AML arises because that’s the whole, you know, carrying out our, our risk assessments, identifying the clients then as well, we’re required to carry out annual compliance reviews, a staff training, which has cost us. Um, if we have any reports we’re required to maintain internal and external reports. And if we have agreements with third parties,

we need to written agreements that we’re placing reliance on them. Um, not, not, I know if I was an accountant and practice it, that last point, it’s not one I’d be too happy with, with relying on someone else to do my AML. What if you do have that situation in place, you should have a written agreement with the third parties.

Quite sometimes you might see that whereby it’s an accountant’s relying on a solicitor. If they’re, I don’t use their parts of the same transaction, that there’s a written agreement that, you know, that, that, that, that, that one party is carrying out the AML housekeepers stuff. And I can’t access the notes. I think Jonathan, if he can post access to the notes again,

that’d be great. Another one, how do we access the arc? We’re really, if anyone wants to get access or subscribe to the arch contact, Jamie M Jamie and the office, and talk you through that, I can talk you through all of the options that are there. Yeah. Um, so I suppose moving on to the business risk assessment or what some people refer to as the firm-wide risk assessments,

you know, the term risk assessment is used. Um, but we need to distinguish our business risk assessments to the risk assessment we do on clients, because they’re two separate things. So what we’re talking about here is a business risk assessment. So our risk assessment on the part of the firm, whereby we look at ourselves as a firm and we look as well,

what clients do we have in this sector, this sector, this sector, I look at an overall risk profile for the firm. This is a requirement, as far as I’m aware, since 2018, that the 18 update brought, brought this in. And it requires a designated person at accountants to complete a business risk assessment, which takes into account the following risk factors,

or what type of customers do we have, you know, risk is posed by the types of customers that we have, um, wash, uh, what products and services are we providing. So, you know, are there any risks or services that we’re providing? Um, do we have any clients in countries or geographic areas in which the, or,

sorry, we look at the countries or geographical areas in which, um, the, the client operates since we have any clients in, in higher risk countries that present a higher, a higher risk of noncompliance with AML. So, like I said, the financial action taskforce have the kind of a list maintained of higher risk countries and where we have clients from,

from those countries that they would present a higher level of risk, not necessarily that not necessarily that they are riskier, just that there’s a higher level of risk presence or a higher potential for risk. So what delivery channels do we use? Do we have any clients that we never meet face to face that we always deal with by email, et cetera? So obviously face to face is lower risk than a client that we’ve never met face to face.

And are there any other prescribed risk factors? So I can go to go to page 50 of the book that just cause this one size it’s new in the sense that it’s a, I think it came out in 2018. So it’s worth just spending a couple of minutes just to show what it, what does it, what does an example of a business risk assessment look like?

And again, this is a template coming, coming from the arc. Um, but it’s just a, I’ll say populated with an example. Yeah. Obviously it needs to be taken and caterer, depending on the, on the, The circumstances on a couple of points, obviously it needs to be done on an annual basis. So, you know, you,

can’t just basically, you know, hock it out today or whatever, and leave it there for the next, the next couple of years, you know, I, as part of your, as part of your, you know, your annual, your, your, your, your positive procedures say review to make sure they’re up to date, this needs to be done as well.

Like, you know, and I think for, I, you know, reviewers are looking at that too. They’re looking for your, your, your annual far wide risk is our business. Yeah. Uh, and, and again, it’s, it’s, if you haven’t done one of these in a couple of years, or if you’re not familiar with these,

it’s likely that there’s no villain, and it is a document that the reviewers will look for when they come in as part of the parts of the review. And I did something that they, you know, they did place quite a bit of emphasis on. So, I mean, I’m not going to go through all the questions on this. This is more just to give you an idea of,

uh, of, uh, what it looks like. So, I mean, we’ve, it’s populated with a lot of questions. Has the firm introduced AML procedures? Obviously, if the, if the answer is, yes, that’s lesser risk. If the answer should be yes for every firm, but if we don’t obviously that, then that there’s, that’s more risk.

Um, you’ll have staff receive training again, this obvious low, low, medium high risk, depending on what the answer is for that. Uh, and do staff receive training on commencement of employment within the firm? Hopefully the answer to that is yes. Um, do we know all our beneficial owners? And again, you can kind of see that the,

the questions kind of give an Indic indicative level of risk. And so following that, then we can arrive at a conclusion of low, medium, or high risk for our firms. So again, it’s, I suppose it’s a little bit procedural in nature, but it is a requirement to have the, of the legislation. And it is something that the,

that the reviewers will look for. So that the conclusion at the end of it all should be, you know, w whether, whether we’re low, medium, or high risk. And I think, I think, I think the point a point for everyone to bear in mind is, is that yes, you have this document prepared and it all looks great.

It’s all completed, or be aware that as, as, as, as the monitory process that are going on from, from ECE institutes, we know that they’re going to be looking into a lot more debt, adapt into the firm, why risk assessment. So they’re going to be looking for what is like under the underlying factors that you’ve been able to,

you know, give yes or no low, medium, or high risk and under comments, but that’s where they are going to be looking for, you know, the underlying, underlying data that backs that up. So how will you come to that conclusion in a particular question, and it’s, it’s low or medium, so it just take time and doing,

and just bear that in mind. And eventually they will start looking for, okay, well, how did you come to your conclusion? And that, and that’s probably a good example of, of maybe how the institutes approach has changed over the last year, year or two. You know, when these came out, it was nearly a case of what have you learned on yes,

we have. Okay, we’ll move on. Whereas now, now the institutes are taking the documents. They’re looking at it in a lot more detail there, you, you know, you might be subject to a bit more challenge based on the responses and based on the reviewers discussion with the partners. So until the customer due diligence, um, you know,

this three steps really, you know, we gathered the information we risk assess, and then we gathered the evidence based on our risk assessments. I suppose, if you could sum it up in a couple of lines, you know, you know, your clients know your business and documents and document those two things, you know, it’s, and again, it’s one of,

it’s one of the procedural things, but it has to, it has to be done. We have to evidence how we’ve assessed our clients, how we’ve decided whether, you know, simplified standard or enhanced your diligence, and then how we followed our procedures to apply that. So what are the key components of good CDD? Okay, we go identify the clients,

we identify it. We verify their identity by obtaining documents and any other information from, from independent sources, we identify the beneficial owners again, that that’s, that’s important. So we know who the beneficial owners are, because then we know who, who to conduct the CTD on. Let me confirm the intended purpose off of the business relationship. Uh, again,

the concept of, of beneficial owners, you know, in our typical example of a company, uh, you know, 25% or more of the voting rights constitutes a beneficial owner, I think previously it was 43% or something along those lines. And, you know, potentially that that presented you might drop, but at the moment it’s 25%, uh, partnerships,

anyone who controls the partnerships again, that you’d be looking at the percentage boarding rates there, um, trusts, um, you need to do a little bit more work on trusts, just look at well, who are the sectors? Who are the trustees, who are the protectors. And again, if you, if you went to the CCA VI guidance,

there’s a few good working examples. There probably, you know, more kind of complex situations where the answer might be that obvious. So there’s good guidance material within, in the notes back there. Yeah, I think I, actually, I question, it’s just come in here now on almost on the, on that exact thing. So at the current,

the question is even if a client is a sole trader who dies and an executor is appointed, well, you don’t, most of the executor be risk assessed. My understanding is that basically, yeah. Dot DM if it’s an estate, but I deceased person, the beneficial owner is the actual executor or the administer of the estate. So that’s who that,

not to the, um, the, the, Because what you do diligence would need to be done on. Yeah. That’s my understanding as well. And I have a feeling, although it could be wrong. I have a feeling that that point is covered in the CCA BI guidance within the manual, but I could be wrong on that because I think,

I think it’s included within there, but that’s, that’s correct. Um, so the, so customer due diligence, again, one of the important things is we complete our customer due diligence before entering into a business relationship with the clients. So before we act for them, we should have, we should have this in place. Obviously COVID-19 has created a few issues as regards to the practicalities of bash,

which we’ll discuss towards the end of the, of the session was it should be completed before we enter into a business relationship, it’s carried out on an ongoing basis. So we don’t just identify the ones they want and then forget about it. CGD should be an ongoing process. So, you know, if, if I don’t, if I’m beneficial owners change,

if, um, passports go out a days, things like that, you know, we need to be updating that because they are the kind of things that our viewers wouldn’t pick up on. Um, and if, if there’s anybody I, um, acting on behalf of the customer, you should be identifying those as well. Okay. And then, and then in turn,

like in terms of, in terms of general, general customer due diligence. Okay. So in terms of, in terms of a coping, so I quit, I queries coming to here, so it’s a bit long. So bear with me. So a company who has a number of corporate shareholders and each with multiple directors, and so in term, in terms of thoughts,

in terms of thoughts, situation, and if you’re, if you’re doing your CDD for the particular particular company, it’s the directors that you’re looking at, not the actual, you know, not the, not the, not the shareholders themselves is actually the director. Those who are, who are in a role of management, that’s your customer duties, obviously bearing in mind,

you’re also looking for the, the, the ultimate beneficial owner as well. Yeah. And you should, you should demonstrate. So I mean, a common, a common issue on, on reviews as well. It would be, you know, you have that situation. If a company owned by another company owned by another company, and sometimes they will look at the company,

but they won’t look as well. What’s, what’s a Beauvoir. Is there any beneficial owner if we follow the company’s till the end? So we should be following those companies no, right up to it, it’s beneficial owner, but should be demonstrating, you know, we know who who’s involved in, the companies who controls the companies. And as you said,

we need the directors as well. We need to identify those. Yeah. So, so, so also the focus on the, the ultimate or the beneficial, or the beneficial owner and not actually be all the other individual shareholders. So obviously our yard, you know, the Copa that you’re looking at, it’s there it’s those directors and those people who are,

who are, who are in dock roll. And then I’m sorry to just is you’re going up to the corporate structure to find out who the, who the beneficial owner is. Okay. I think we’ve got a bit of clarification on the MLRO director reporting to the director reporting query. So if we have a firm with two directors, one is the MLRO,

the other mics report though, consultation or agreement of the director, who is the MLRO. Um, so, you know, that would probably be, would possibly be, not be in compliance with the policies and procedures that the firm has in place. So the procedures would stay spec the money laundering reporting officer makes that makes the reports. So that situation,

if someone goes, they’d be above, or are those mixed reports without consulting with the MLRO? Well, then that’s, that’s not in line with the firm’s documented policies and procedures. So that should go through the MLRO. Um, so what kind of events prompt the customer due diligence updates? So change in client, in client’s identity, you know, any change in the beneficial ownership.

So there’s a new shareholder, common boards that do we provide different services to the clients. So maybe we took on the client and they had one warehouse making furniture, and now they’ve got 20 warehouses making furniture. So I would say that’s actually a further example, but you know, if, if circumstances like that change, well, then we need to reassess and,

okay, well, are there any other factors that are now at play because of the change in the nature of the, of the clients are, do we, do we provide any different services? So what do we do now? We do tax work or do we know, do whatever corporate finance kind of work, uh, how we, we need to CDD update if,

if a client ever gives us information, that’s inconsistent with the firm’s knowledge of the client. So again, we need to factor that in, and we need to see where the client’s been, where the client’s truthful with the information when they get, which wasn’t the first place when we start to new engagements, any, any planning for reoccurring engagements, do you know,

has anything changed in the, from one year to the next, where we restart and engage. If the client engage those, we stopped acting for them. And then we restarted again. Well, then we need to, we need to go back and update our CDD. Um, you know, significant changes in key office holders involvement with pep. So how has it,

has the client either become a pet where they weren’t previously a pet or have we had, has a new shareholder come on board, that’s a pap. And as a result, then we need to go and look us enhanced due diligence and change the finance business activity. So are they not doing something totally different? So those types of situations would prompt a customer.

They’re like, I just like the duck dove tails or, or ties into the whole concept of, of ongoing monitoring. And which I think is something that basically that the reviews are picking up a lot on there. They see any evidence on the files of ongoing monitoring, you know, and I think, I think, I think you to make some very,

very important points here, that’s, you know, all of these were projects I CDD update, which is which, which is part of your ongoing monitoring. So, you know, it’s, it’s, it’s, it’s every, within the firm you could buy into the whole AML that like, if they know something, if they’re doing bookkeeping and you know,

they’re on a team as well, that they all leave, tie it all in it’s basically. Okay, well, look, do we need, do we need an update and then use evidence this on your CD, on your CDD forms. And I think in the army pro pack, there’s a section at the bottom of your CDD on your risk assessment to say,

when you, when you’ve updated your em, right, when you, when you’ve updated the documents or when you’ve done your ongoing monitoring on dot should be, that should be in there. Um, it’s an important point there, I suppose it’s important to know too, that it doesn’t necessarily have to be a case of reinventing the wheel. Like it might be the case that the information you have is already used.

It’s just, you need to review with, see, as NFN changes, if that hasn’t changed, maybe sign and date, what you already have. No, exactly. That’s exactly. It’s the evidence, the evidence isn’t there, like w we’re probably all doing this on an ongoing basis. Like, you know, we do a tax return, we opened the file,

picks up and change, go to your AML file notice. So it proves to a review or that you are activity ongoing monitoring your clients. Yeah. Um, so as regards to the different types of customer due diligence standards, due diligence, you know, the vast majority of our clients would, would fit into that category simplified, you know, it’s where we assess them as low risk.

It’s not that common. Um, it’s more common maybe for listed entities and things like that. Enhanced due diligence, again, you know, any, any higher risk clients, any politically exposed persons eye, anything like that. Um, politically exposed persons are automatically enhanced due diligence as a result of, of their, of their status by, by, by definition and the legislation and third party reliance.

So again, are we relying on a third party? So as regard standard customer due diligence, I mean, well, what, what, what do we need if we assess that our clients can, can use standards due diligence by the documents from a government source, any other documents from a prescribed source. And again, we identify the beneficial owners and we carry out,

carry out CD on that basis, a simplified due diligence, I suppose it is there. Uh, it can only apply only assess the fines as low risk. Usually doesn’t apply, uh, the low risk factors, which you’ll see in appendix D to the CCA guidance. They named some things. So companies listed on a stock exchange, public administrations, okay.

A lot of clients would fit into this low risk geographical area, but then they might meet any of the other factors, life insurance policies, insurance policies for pension schemes. It’s very minimal situations that, that, that would apply. So you still are required to do your risk assessment for the firm, or, you know, to demonstrate that that’s simplified due diligence kind of place you still your risk assessments,

or obviously the CDT part of that game. Isn’t the business or the, the identification participant requires enhanced due diligence. And again, that’s when we assessed the planet as higher risk. And if we go to appendix D of the CCA VRD guidance, which I think is on to page two 66, or, uh, maybe further than that, uh, so these are the high risk factors.

And again, these are the factors. If we look at these and take these into account, they’re indicative of a higher level of risk. So the business relationships is conclude is conducted under unusual circumstances, a higher risk geographical areas, non-resident customers. Um, you know, I’m not going to go through all of them plus, you know, private banking,

non face-to-face, uh, things like that. So you can kind of see if there’s, you know, there’s, there’s a good few high risk factors there. And That’s what I think, I think, I think the important, the important thing to note is basically is that w however you wanna pick it up on is basically how firms have categorized their clients into,

into how you meet your high, medium, and low risk clients. So it’s, it’s completing your, your risk assessment forms and your customer due diligence, the forms I’m really teasing it out as you come down to the fact that they’re low or medium risk, and then concluding on dusk. So you need to conclude what the risk is, and based on that,

what type of CDD you’re doing, and that’s gonna, that’s going to give you the, give you the pushback on the reviewer saying, but look you are, you know, why don’t you have any higher high risk clients? Well, a low risk, because here’s our risk assessment. These are criteria. Here’s how we do include it in upon. Well,

you know, you know, you tell me about more, do you want me to do it? Don’t fall into this higher risk categories. And we’ve referred to our M PARCC ABI guidance, and there there’s no higher risk factors, or if the race is already more of a, of a number of other low risk factors, I think that’s what the,

that’s what the institutes are pushing are looking at. They’re looking at the categories of clients. You have, it’s going to be all of these ones, like apps will have to be at a heightened risk. And how’s your dealings with the other ones. You need to be careful about how you document your risk assessments. Yeah. And again, when we look at enhanced due diligence,

you know what I mean? It’s probably stuff that we’re already doing. So, I mean, what must you do if you have a claim that’s that, that has enhanced your diligence applied. And again, this is the CCA BI guidance. So as far as reasonably possible, examine the background and purpose of the engagement, so understand, you know, what you know,

but what does the client do undocumented? It is kind of the important thing for all of these points increase the degree and nature of monitoring of the business relationship in which the transaction is needed. So, I mean, we just, we carry out more frequent monitoring and a nature of the transaction. So, I mean, if you have a, if you have a politician and,

uh, obviously by definition of politician is a pep, so it must have enhanced your procedures. You know, if all you’re doing for them is farm accounts or, or whatever. And, you know, you’re, you’re looking at the farm accounts. You probably carry out a bit more scrutiny when you’re, when you’re doing those accountants. And let’s see,

then if you see, I don’t know, consultancy income or something within that, obviously then that would increase the degree of suspicion. So it’s kind of that, that’s how, that’s what you must demonstrate in your CDD forums. How, how are you going to address that CGD measures may also include, and then again, that’s, that’s me. So you kind of,

you can use these as appropriate, um, seek additional independent, reliable sources to verify information. I’d be in trying to do that anyway, because it’s an easy fix and it, a Google search will achieve that point, uh, take additional measures to understand better the background ownership and financial situation of the client. Take further steps to be satisfied that the transaction is consistent with the more present intended nature of the business relationship and increase the monitoring.

So including much greater scrutiny of transactions. So that’s what enhanced due diligence should look like. And that’s what should be documented on your enhanced due diligence section of your, of your forums. Um, so politically exposed persons. And again, I’m conscious of the time here, uh, heads of state, head of government, government minister, a member of parliament.

So typically that that would be your governments, uh, whatever your TD and Senate member, it doesn’t extend down as far as County counselors or anything like that. But you may wish to, you know, if they sit on committees or, you know, housing committees or planning committees, you may factor that into your risk assessment, which may drive a higher risk assessment,

but by definition, they don’t meet their requirements or their definition of politically exposed persons. How you level a member of the judiciary high level member of the armed forces member of state or state owned enterprise. And as well as ashes includes family members and neutrals associates. So your client mightn’t necessarily be the public, the politician or whatever. What do you might’ve felt?

Wife, son, daughter, whatever. Um, again, we’ve spoken about third party reliance, uh, as regards copies of copies or originals, uh, you know, where we’ve cited, the original document. We should note on the copy that we’ve cited this, um, and where it’s been provided by the internet. The firm should annotate the documents that’s been picked up.

So that’d be picked up on laundry visits. So you don’t be careful, make sure you have annotators annotated the antidote appropriate that they are true copies, true copies of the originals. And the schools are fat. That’s an important one too, because you know, people assume that, you know, you know, people assume that they can’t afford a copy of something that it’s not forged to put.

I mean, you know, even you mean yesterday weekends, but then when they, when they looked at the Irish bank accounts, they were set up using fraudulent documents. So I think that was in the times yesterday, but it’s, you know, don’t assume the documents documents are always legitimate. We have to demonstrate, okay, well, it’s, it’s a whatever,

a true copy of the original, and we should be citing the original one, the original documents. And then we should also be showing that’s how we’ve demonstrated with that because the reviewer will look to see, to see, have you written them on the forum certified to be a true copy of the original. I questioned this comment, actually quite, quite a common question as well,

actually we would get, so a particular client company has a large number of directors. So does Antinori laundry has to be carried out for each director, or can you concentrate on the key directors who are involved in the day to day management? Yeah. So what we look at there is the beneficial ownership. Um, you know, if there’s, we look at the shareholdings,

if there’s any particular, you know, whoever meets the definition of a beneficial owner, um, if, let’s say for example, if it’s, if it’s, uh, a CRG, well, then we need to, you know, obviously there’s no person with more than 25%. And if we look as well, who’s defined as the beneficial owner, it would tend to be all the directors that will be,

that will be categorized within, within that. So in that situation, we would have to look at all the directors, but you would have to look at well, who’s the, who’s the beneficial owner by definition. And then probably the CDD procedures to those I, you know, from a practical application of it, you’d be starting. I, I,

as the creator, you said, you’d be talking to those who are actually in the day to day management, who are, who are, who are making management decisions and then work your way back. But I did want to exactly your point is Yes, new grid get the wall. Um, so as regards to reporting procedures at school, you need to have clear procedures as to,

uh, how, how, and when we make reports either internally or externally, and we discussed tipping off already, it shouldn’t happen. I mean, if, uh, you know, if we’re making a report, to be honest, at one end of the scale, tipping off is telling the clients, we’re making reports as no other end of the scale is our behavior suggesting that we’re going to make a report.

So we need to be careful best that client isn’t tipped off because obviously then Beth can talk to you, prejudice any, any subsequent investigation. And it it’s, it’s, uh, you know, it’s a fairly severe offensive if anyone is caught doing it. And so we need to report suspicions at the guarantee and the revenue commissioners, where we have knowledge,

our suspicions are reasonable grounds to suspect that another person has been always engaged in money laundering or terrorist financing. And I suppose the common question that we’d often get caught on is, you know, someone will come to us with a situation and say, Oh, this happened, or that happens. You know, I think money laundering has a, has a cards.

Do I need to make a report? And I suppose the answer there is if you suspect it, you’re not required to be judged jury and executioner here, you can, if you have suspicion of anti money laundering, well, you need to make a report. And there’s some good guidance in that CCA, BI guidance documents of, well, what is suspicion and what is knowledge?

Uh, well, I’ll tell you what is, uh, w w w what is knowledge and must? What is suspicion, what isn’t suspicion, you know, it’s not, it’s not a mere idle wandering, but you know, it kinda presents various situations as to, as to what it is, um, you know, cause go, go away and I let the guards,

they don’t want to be getting kind of speculators with reports. This at every single suspicion is going in, if something is serious enough and, and it’s significant enough where that should be reported. So that there’s good guidance within the, within the CCAP guidance off that, uh, it would be the knowledge or suspicion must arise in the course of carrying it on businesses and accounting firms.

So not, not, not things that you find out in your personal life or down in the poker or whatever, it’s in the course of carrying on business as an accounting firm. Um, you must scrutinize the information and, you know, probably part, and if you, if there’s any dose, you should seek legal advice. Okay. Okay. So if we,

if we do have to make a report, what needs to be reported, uh, not the identity information, uh, on which the knowledge or suspicion has there, isn’t the identity of the suspect or address whereabouts of launder, property details of bank accounts, et cetera, et cetera. So, you know, I suppose as much information as you possibly can and guests and the reports,

there’s two ways you have to make a record. So, uh, we have, we have go AML, which the link is to there. Every accountant should be set up or should have a profile set up on that. Even if you don’t have any reports to make that the profile should be settled. Um, so that that’s quite a sophisticated online portal whereby you know,

there’s various stakeholders involved. So let’s say I’m an accountant. I send in my suspicious activity reports, you might have a solicitor acting on behalf of someone else. They send in a report, you might have a banker, they send in a report. And there’s kind of like a way of every bit of information that goes onto the goal EML website. Then,

you know, you might think that what you’re sending is insignificant both. It’s a, it could be a kind of a piece of the other larger jigsaw. I think there’s a question coming in here, or, you know, a general would accountants typically make many STRs? I think this is, I think this is the, the big complaint yeah. That over the,

over the regulators hive or the over regulators have about accountants in general, I don’t think there are many reports from accountant and altruist and, and probably, you know, you know, it’s, you know, we’re not, we’re not Lord hounds. It’s just the turbine per use. You know, as in, you know, if, if, if one is there you should be expecting to make the report and this night you’re going,

looking for them. Typically I can take there’s many reports go in as opposed to other sectors like the banking sector or particular potentially solicitors. It is probably unexpectedly low. That’s probably a fair comment to make, isn’t it? Yeah, I think so. I, I think that’s the complaint that, um, and I think that, I think in the last,

in the last, over the last Irish, the Irish am risk assessment at the country level, the medium category specifically because of that, because of their access to information and the low level of reports that I’ll be making. Yeah. So again, go AML website. That’s obviously a very sophisticated website for revenue commissioners. We print off a report, what we send to the AML and we post the two of them.

So obviously the, that hasn’t gone paperless. So it’s, uh, I think it’s the, uh, the address and the<inaudible> the address for forest. So again, just to make sure that if you are submitting the report, it needs to go to those two cases. Um, when is the report not required? So if there are situations whereby you kind of play legal privilege,

professional privilege, again, it’s, it’s a, it’s a legal concept, more so than an accounting concepts. Uh, it may apply in circumstances, let’s say whereby a fine comes to you and asks you to rectify your tax position. And then they want to help you to make a voluntary whatever own prompted voluntary disclosure. It may apply in those situations.

But what I would always say is where you’re planning on applying legal privilege. You need to get legal advice because it’s a legal concept and you need to, you know, you need to get legal advice, but just be aware that there is a concept, I call it professional privilege and it may apply in some situations where it can be used, you know,

taxation, litigation, uh, business law, direct, uh, juices of a director, insolvency law, employment law. Typically it doesn’t apply to, to the legacy, your work and things like that. You know, just be aware that it’s there. And obviously if you’re planning on using these, I’d certainly seek advice. So we spoke about the fifth money laundering directive,

which is yet to be an actors and the actors. It was due to be transposed in January, 2023. We’re already well, late on that. And given where we are both in the worldwide stage of things and also our government, you know, the fact that we’re, uh, you know, so along with other governments, I wouldn’t be holding my breath as regards to that being implemented.

There’s was probably probably bigger things on the place of the Colombian government. We can expect it’s to be implemented. You know, I’d say 2020 is probably probably a bit of a push, maybe 20, 21, the sixth directive then is also due for implementation by December. But again, I wouldn’t hold my breath in baskets, um, as regards what what’s,

what’s going to change, um, from a practical point of view, not an awful loss, uh, you know, there’d be more transparency, um, as regards to beneficial ownership, uh, Bitcoin blockchain, or that they’re kind of going to be covered a bit more, um, enhanced power with the financial intelligence units on a day to day basis for accountants.

I don’t think an awful lot will change. Um, so again, I’ve got to finish off just kind of discussing COVID-19 and how that has impacted. Uh, obviously it’s presented a lot of challenges and, you know, when we talk about things like you can find face to face and things like that, have we moved would have taken for granted before Huns,

uh, you know, things are maybe coming back to somewhat, I’m not going to say normal because it’s not normal, but things are getting a bit more structured again. So hopefully the whole thing of, you know, get notes, meeting clients face to face, you know, hopefully that will normalize somewhat. Um, there was, I think it was the ICA w issued guidance there recently.

And I know some of the Irish accounting bodies were kind of advocating this and I, I think it was kind of saying, well, we recognize that it’s a difficult time. We recognize that, you know, you may, there may be delays in getting AML information, or you still have to comply with your, with your, uh, with your requirements.

So, you know, on the one hand to say in Welby, we understand that it’s a difficult position, but you still have to get C you still have to get your, um, your EMR documents, but hopefully that’s an area that will be getting easier as the, as the time goes by. Um, just a bit of commentary, I suppose,

more so on the UK, America is a good source of information for AML is the national crime agency website in the UK because they issue a monthly newsletter. It gives a lot of, kind of up to date information as regards to what ha what’s happening from an EMR point of view. Um, I think this is from the March or April, and then also a spike in what they call COVID-19 Cyrus.

So they had 27 in a three day period. So these are the sirens, by the way, this is probably an unfortunate acronym for where we are with Sarah is a suspicious activity report. Um, so basically suspicious activity reports sent in by an accountant reporting their clients because, because of something that was occurring as of COVID-19. Um, so the typical things that,

uh, that they’re seeing in the UK, um, plants making large deposits companies citing COVID-19 as a reason for payments. So let’s say, let’s say I have money that I want to launder. I have a company that’s whether the UK using the photo scheme in the, in Ireland, whatever it’s shutdown. I, I liked my money into the company as a kind of alone and on the face of it.

It’s, it’s kind of money to, you know, to tie it to the company over most, in reality, I’m putting laundered money into a company after the director’s loan, which I then take out in, in whatever my payments come back to normal. So again, that that’s, that that’s some of the reasons that they’re seeing suspicious activity reports, things like large ones for companies claiming to be a refund of flights.

Again, business owners, making deposits for staff wages business is an interesting one, because there’s a sense that should be closed that have continued to trade. So I don’t know, let’s say if you had to have a poll and obviously in Ireland, your pubs are closed. Let’s say that the company is still taking in money. So some accountants in the UK that have sent in suspicious activity reports because,

you know, there’s no reason why this company should be, shouldn’t be continuing to trade, but they are continuing to trade. So that’s kind of an example of some of, uh, puff of some of the, uh, issues as regards suspicious activity reports relating to COVID-19. And it’s interesting Just before we close a good question, I was kind of calming and actually here,

and if a category person operates a client bank account, I’m assuming that money laundry has to be carried out on money’s being lodged to this account from non-clients 100%. I think all of these two top very, very tight regulations are regarding client monies in general, about what monies go in and go out on the operation and included in that are really tight and anti money laundering procedures.

So very much so that needs to be tied into your, so if your needs are tied into your general, um,<inaudible> procedures, and you may need specific Clyde Mani procedures or procedure included in your overall and in your overall, but yeah, you can’t just let money come in and go. Now you’re trying to counter whatever anti money laundering and, and,

you know, reasonably transact the reasons for the transactions. That’s what Michael said. All right. Who in the habitat, who the person is reasons and various things like that. I, that’s a, that’s a good point because, you know, quite often they’re a client account for an accountancy practice can be seen to legitimize legitimately dorky money. So, you know,

I, if I had, if I had proceeds of crime and you, you were an accountant with client money accounts, and I give that to you, and then someone else has received that money. Well, the money that’s been received it’s came from an account and it’s come from a client account. So it can have a layering effect of affair of legitimizing effectively what you call dr.

Kimani. So again, it’s anyone with a client bank account. You need to know the reasons why they’re trying to be from the bank account and you know, what, what’s the, what’s the purpose of the transaction. And one final one I leave with is, is, um, another suspicious activity report that I haven’t put on here, I think relates to large shipments of PPE.

So not property plants and equipment that the personal protective equipment and, uh, you know, payments coming through for PPE, but then there’s actually no contract in place for PPE. So again, that’s, that’s another reason why, um, suspicious activity reports have been submitted. I put two links in there. Again, we’re not going to have time to go through them and have a look at them and follow the links again.

If you went to the national planning agency websites, it’s, there’s a newsletter section on that. Again, I don’t think we have the equivalent of this in Ireland as regards a newsletter for anti anti money laundering purposes, but it’s, it kind of gives good guidance as recurrence watch as regards to watch what’s been encountered. So I suppose that’s kind of, that’s kind of a,

I know we’re kind of just gone over time. So there’s a, there’s a few other slides that we didn’t get to post that’s more or less. I’m not sure if we have we any questions. I think we’ve covered off all the questions like, so Mike look brilliant timeframe, much like that. And I thought just kind of brings us to the end of this session and yeah,

look, thanks a lot. That was brilliant. Really, really a forms as a whole people got this, I’ve gone have, have taken account of it. Like, so am, I think we have a 20 minute break now and until 1220, and then we have the next session with John<inaudible> who was costing tax appeals in 2020. Thanks everyone for attending.

And I hope you find it beneficial and placed them like for his valuable insights into AML. And look, you know where we are. If you have any email queries knowledgeable, well, the true they’re in cost down to whoever am and deal with it. Thanks Jonathan. For his it support, that’s it? I think we see in the breakout room on enjoy the rest of the day.