This additional support aims to provide more clarity and signposting around common AML issues.

Please note that the AML Toolkit page may also hold important items for you to consider.

Flag it Up

The Home Office, in partnership with the National Crime Agency, has been working with the accountancy and legal professional bodies to raise awareness of the warning signs of money laundering, and help professionals protect themselves and their firms through the Flag It Up campaign.

Money laundering through the legal profession continues to be a real threat - please do take a look at their website Flag it Up - it may just help you protect your practice from becoming the unwitting victim of those with criminal intent.

'Politically exposed persons' (PEPs)

A "politically exposed person" (PEP) is a term describing someone who has been entrusted with a prominent public function. They generally present a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.

Such positions may include:

  • Head of state, heads of government, ministers and deputy or assistant ministers
  • Members of parliament
  • Members of supreme courts, of constitutional courts, or of other high-level judicial bodies - members of courts of auditors or of the boards of central banks
  • Ambassadors, charges d'affairs and high-ranking officers in the armed forces
  • Members of the administrative, management or supervisory bodies of state-owned enterprises

The definition of a PEP also extends to:

  • family members of a PEP - spouse, partner, children and their spouses or partners, and parents
  • known close associates of a PEP - persons with whom joint beneficial ownership of a legal entity or legal arrangement is held, with whom there are close business relationships, or who is a sole beneficial owner of a legal entity or arrangement set up by the primary PEP

This applies to both UK and foreign PEPs.

The identification of PEP status should form part of client onboarding and ongoing due diligence. Practice units should consider and assess the heightened risk of undertaking business with or on behalf of PEPs, particularly the risk of laundering the proceeds of corruption.

Where a practice unit chooses to enter into such business, enhanced and on-going due diligence measures should be applied.

FCA Guidance on PEPs

Jurisdictions and sanctions

There are several jurisdictional risks which you should assess when considering receiving funds or establishing a business relationship. There is no single authority on these - some reports consider bribery while others consider Money Laundering controls, for example.

There is no magic bullet to risk assessing these countries and your related transactions, but you should consider the following resources as good signposts for risk.

Know Your Country

Various Pertinent AML Maps

Financial Action Task Force

Remember a high-risk jurisdiction is not the same as a sanctioned jurisdiction. You must not enter into any transaction with sanctioned jurisdictions or persons (without a HMRC license to do so).

UK Sanctions Guidance

UK Sanctions List

Specific ID & V Guidance