The vast majority of the Association's Members are accountancy service providers and as such are 'relevant persons' subject to the Money Laundering Regulations.
All practising CPAA Members must be supervised by either a Professional Body Supervisor (PBS) or by HMRC as the default regulator for accountancy service providers.
The CPAA is not a PBS, but does nevertheless require its Members to be compliant with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) legislation and applicable guidance. This includes ensuring that all Members in practice are supervised for AML/CTF compliance and supported in doing so by the CPAA. All Members have access to a unique support package which consists of a compressive guide designed for practitioners and a collection of templates which can be customised according to the Member's circumstances. CPAA Members also benefit from a dedicated AML and ethics support line and regular AML focused CPD led by industry experts.
AML requirements for practitioners
All accountancy service providers must be registered with a PBS or HMRC as the default regulator for external accountants and tax advisers. The PBSs are themselves supervised by the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), which sits within the Financial Conduct Authority (FCA). A list of current PBSs and more details on OPBAS can be found here.
Accountants who are not supervised by an accountancy PBS must register with HMRC. Details of how HMRC supervises can be found here . Those looking to register with HMRC for supervision can do so here.
Many accountancy practices will also be classed as ‘Trust or Company Service Providers’ (TCSP). The provision of company formation services, providing a registered office or business address service for a company and acting or arranging for another person to act as, an officer of a company (including acting as a Company Secretary or Director) – all fall within the definition of a TCSP. Accountancy practices that also offer TCSP services will need to ensure that they are supervised for these services in addition to being supervised as an accountancy service provider. More information can be found on HMRC’s website here. Those practisioners supervised by a PBS should contact them if they believe they are are also offering TCSP services.
The Consultative Committee of Accountancy Bodies (CCAB) maintain AML guidance for the accountancy sector, which is approved by HM Treasury. This guidance can be found here.
CPAA support for Members
Maintaining compliance with the Money Laundering Regulations can prove challenging for many practitioners, most of whom want to get things right and contribute positively to the UK’s efforts to fight economic crime. To help practitioners get things right the Association offers its Members a series of tools and services designed by industry experts.
AML Support Tool
Our comprehensive AML Support Tool is delivered primarily though our Member exclusive site CPAA Zone. It is available free of charge to Members of the Association. PDF and MS Word document versions of the AML Support Tool are also made available exclusively to Members.
The AML Support Tool consists of a comprehensive guide designed specifically for practitioners and a series of template documents which the Member can customise and use within their practice. Convenient digital forms are integrated into the Tool which enable Members to easily start using the templates by populating them with key details relating to the Member’s practice.
We have received extremely positive feedback from Members who have used our AML Support Tool. Many have commented how useful the tool has been in helping them prepare for visits from their supervisors and engaging with AML/CTF compliance.
The Association recognise that AML issues can be unique to those encountering them in practice, and it often helps to be able to talk a question through with a subject matter expert. This is especially true for sole practitioners who often have no one to ‘bounce’ things off. The Association provides all its practising Members with access to an AML support line, putting them in touch with a subject matter expert who can help guide them.
CPD and training
The Association provide a compressive CPD program to all Members inclusive of their membership fee. Several of these sessions each year focus upon AML compliance each year and are led by subject matter experts. Live sessions enable Members to directly ask the expert any questions they may have on AML/CTF compliance.
AMLCC is a digital compliance tool that can help practitioners meet their compliance needs. CPAA Members are entitled to a 20% discount on their first year of AMLCC. More information on AMLCC can be found here.
All Members must be supervised
How do we ensure our Members are supervised?
As part of our application process all applicants are required to evidence that they are supervised. For those who are supervised by a PBS this will normally be a copy of their practising certificate and proof of payment for their AML supervision. Those supervised by HMRC must provide a screenshot of their GOV Gateway account showing their status, along with their reference number which is checked against HMRC’s records.
All existing Members are required to complete an Annual Return Form issued by the Association, each year. On this Form the Member is required to declare their supervisor and to evidence their status.