Just before Christmas we sent all firms in scope of the 2017 Money Laundering Regulations, a copy of the questions to be answered in the AML Certificate 2019. You can also find this document on our AML Certificate website page
If you are not sure whether you are in scope of the Regulations, you can find further information about the activities which bring a firm in scope in our new AML Certificate notes for completion. If you believe that you are exempt, you should contact us at email@example.com as soon as possible or click ‘Claim Exemption’ on the landing page of the AML Certificate in the portal.
With only two weeks until the online portal opens for the submission period, I would urge all our members who are in scope of the Regulations to look over the requirements of the questionnaire and begin to collate the necessary data sooner rather than later. The questions are not identical to last year and, depending on your internal information management systems, you will need to spend some time preparing your answers. This is particularly true in the ‘Services’ section which requires actual ‘numbers of transactions’, rather than percentages (‘transactions’ in this instance refers to any relationship/service for which a fee note or interim fee note was rendered within the relevant period).
We do accept that numbers may be difficult to provide with 100% accuracy, especially in this first year. We have also spoken with various software and case management providers about their ability to amend their systems to allow collection of relevant data at ’point of sale.' This would make it easier to prepare the answers in advance of the annual submission period and we will keep you up to date with any developments in this initiative.
When the portal opens for data entry on 10 February, you will see that it contains information boxes next to many of the questions which will provide more information on how to answer. You might also find it useful to refer to the answers to Frequently Asked Questions on our website as well as a new set of AML Certificate completion notes which you should review before sending any remaining questions to firstname.lastname@example.org.
The submission period for the AML Certificate 2019 opens on 10 February and your certificate must be submitted by the 10 April deadline.