Following the recent round of FCA thematic reviews of Anti Money Laundering AML Controls, IFAC have introduced automated AML reports.
Using IFAC's software BAT, the system will pick up the minimum requirements and request confirmation from the firm's CF11 that these procedures are in place.
All firms should download these reports from BAT and save before the end of February.
IFAC introduced the AML reports following a recent FCA interview with one of their firms.
The visit was a relatively straightforward Anti money Laundering thematic review visit by the FCA to a small IFAs firm.
The format went something like this.
<> FCA MAN
So you use a risk based approach? (oh good!)
Have you filed suspicious activity reports?
No – we haven’t had any suspicious activities.
What are the key issues in your latest MLRO report and what issues did they highlight?
Not as well documented as it should be….but we did a review.
Were any PEPs found?
No, we found no PEPs.
So you never completed a AML Report?
So mindful of the question in bold above.... IFAC have hastily put together an Anti Money Laundering Report document onto BAT for you to complete and download for your own firm.
This is a major step forward in self–service compliance!
We urge all IFAs and MGI firms and indeed all other FCA regulated firms, to undertake the brief questionnaire that is required to generate the report. See diagram shown of the BAT system.
Bat is a complete practice management system, as used by hundreds of firms. Available here for £25 per month per RI plus vat.