Got an AML question you've been meaning to ask someone?

David Winch runs MLRO Support and does a free monthly Ask Me Anything with us for UK accounting firms. No slides, no pitch. You ask, he answers.

No date yet. Register and we'll email you as soon as the next session is confirmed. The question is optional, but if you add one David will cover it.

Questions David has answered in recent sessions

These all came from accountants on previous AMAs. Most of them turned out to have a different answer depending on who supervises you, which is usually David's first question back.

We've got legacy clients we never ran proper CDD on. How much of a problem is that?

A bigger one than most firms assume. Nothing having gone wrong isn't a defence when the supervisor asks for the file.

A client's passport on file expired two years ago. Do we need a new copy?

Depends on your supervisory body. Two firms with the same document can get opposite answers.

Once a client is a PEP, are they a PEP for life?

No. There's a twelve month floor after they leave the role, then it becomes a judgement call.

Four owners at 25% each, so nobody is a registrable PSC. Who do we verify?

Not the answer most people expect. Asked by two different firms in the same session.

A client has a Companies House verification code. Does that count as AML verification?

No. They're separate regimes and firms are starting to confuse the two.

Do we have to ask every client where their money came from?

No. Source of funds is risk based, not a box on every file.

Do our AML policies need an annual review if nothing has changed?

Covered, along with what a reviewer actually wants to see as evidence.

I'm a sole practitioner. Is a one page firm-wide risk assessment enough?

It can be. The templates assume a bigger firm than most of the people using them.

Free and monthly

Online, roughly once a month. Register once and we'll send you the date for each session.

Your questions, not a presentation

Send your question in advance using the form, or ask it live in the chat on the day. No slides and no product demo.

Answers for your supervisor

ICAEW, ACCA, HMRC and the rest don't always agree. David answers for the body you're actually supervised by.

About David Winch

David runs MLRO Support and has spent his career on AML for accounting firms. He's the person firms call when they're not sure what their supervisor will accept, and he gets asked questions like the ones above every month. If yours isn't on the list, that's the point of the session. Add it to the form above and he'll cover it.

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