The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 has already had a significant impact on financial institutions, requiring significant changes to procedures and software systems. The second tranche of designated services will affect everyday services provided by accountants, lawyers and other professional advisers and as a result draw them into the operation of the Act. Complying with the obligations relating to the provision of designated services will result in significant additional obligations which need to be addressed early to minimise the impact. This paper covers:
- the gateway – what are designated services?
- the obligations: client identification; adoption of an appropriate system by the professional adviser; ongoing client due diligence; ongoing record keeping; and reporting obligations
- the sanctions
- the practical impact on your practice.