On 30 September 2020, the Consultative Committee of Accountancy Bodies (CCAB) published updated anti-money laundering (AML) and counter terrorist financing (CTF) guidance targeted at the accountancy sector. This updated guidance reflects the changes made to the UK’s Money Laundering Regulations with respect to the provisions of the 5th EU Anti-Money Laundering Directive, and aims to provide practical support to the accountancy sector in implementing these provisions.

Amongst other items, the updated CCAB guidance highlights:

• the requirement to report discrepancies identified in entries on the UK’s People with Significant Control (PSC) register, which functions as a beneficial ownership database. CCAB suggests that a reasonable timeframe for reporting such identified discrepancies is 30 days;
• use of electronic identification and verification systems is permitted (and promoted) where certain criteria is met. However, accountancy firms are under no obligation to use systems of this nature when conducting customer due diligence; and
• agents to be subject to a firm’s AML/CTF training should be considered as persons who are engaged to perform work or provide services on a firm’s behalf. Whilst agents are not employed by the business on their payroll, their contribution is supervised by the firm (this definition therefore excludes parties such as legal advisors).

The updated CCAB guidance also contains practical considerations to support firms in filing suspicious activity reports, both in terms of internal escalation to the money laundering reporting officer and external reporting to the National Crime Agency.

Finally, the CCAB guidance includes 12 case studies pertaining to the analysis of beneficial ownership structures. This covers a variety of legal entity types, as well as a scenario where it has not been possible to identify the ultimate beneficial owner.

As a next step, the updated guidance will be subject to approval by HM Treasury before formal publication.