This area is designed for IAB members in practice (those members providing bookkeeping services on a self-employed basis) to give further clarity on the way the IAB discharges its money laundering supervision and monitors members for best practice.
What is a member ‘in practice’?
- Sole practitioners
- Limited companies
There is no minimum number of clients – therefore even if you only have one or two clients you are still considered in practice.
If you are on the payroll of a business that employs you for your bookkeeping services and that constitutes 100% of your work, you are not considered to be ‘in practice’.
If you offer your bookkeeping services for no remuneration (i.e. on a voluntary basis) you are not considered to be in practice.
Regulations for members in practice
The most significant of these regulations for members in practice are:
• Holding an IAB practising certificate (or certificate of AML supervision)
• Compliance with the Money Laundering Regulations 2017.
Evidence of compliance is requested at the point of applying for or renewing a practising certificate. In addition, the IAB may carry out a peer review or monitoring visit – either where insufficient evidence of compliance is demonstrated or on a random basis.
Money Laundering Regulations
Click here to access the Money Laundering Regulations – statutory instruments.
Guidance has been produced by the Consultative Committee of Accountancy Bodies (CCAB) and is based on law and regulations as of 26 June 2017. It will be published as final when it’s approved by HM Treasury.
The guidance helps accountancy related businesses meet their obligations for money laundering supervision, including customer due diligence, record keeping and reporting suspicious activity. The guidance can be viewed here.
A legal responsibility of an external accountant or bookkeeper is to register with an anti-money laundering (AML) supervisor.
The IAB is one of the 22 Professional Bodies who have been granted supervisory status under the Money Laundering Regulations 2017 by UK Parliament. The Association monitors members for compliance with the AML Legislation.
Those practitioners who are not members of a professional association can appoint HMRC as their AML supervisor. However, members of the IAB should appoint the IAB as their AML supervisor.
The only exception is if you are already supervised by another Supervisory Body, this should be declared to the IAB as you do not need to hold supervision with more than one body. In this instance you should complete the application for exemption form which can be found below.
How do I appoint the IAB as my AML supervisor?
You appoint the IAB as your AML supervisor by applying for a practising certificate*.
At the IAB we combine the monitoring of compliance with the IAB’s regulations with the supervision of members for AML in one certificate.
The cost of the practising certificate is in addition to the annual membership fee.
How do I apply for a practising certificate?
Use the application forms below.
Money Laundering Supervision is granted immediately upon receiving an application (and payment being made). The IAB will then assess the member’s compliance with the regulations, and where shortfalls are identified, work with the member to rectify them.
*Please note that if you are an Associate of the IAB you will receive an IAB Certificate of AML supervision rather than a practising certificate.
If you are unsure if you need to apply for a practising certificate contact the IAB Compliance team at firstname.lastname@example.org.
Guidance for members in practice
- IAB’s Framework of Regulation and code of best practice for members in practice
- Money Laundering Regulations
- Appropriate standards within their own practice
- Any other legal requirements that apply
To assist in understanding these obligations there is a short guide that gives help and advice.
Being a pdf document, the guide is printable. However, as it contains many useful hyperlinks to IAB resources and other websites you may prefer to keep it in electronic format.
Continuing Professional Development
Keeping a record of your ongoing learning and accruing Continuing Professional Development (CPD) points for it, is a method of demonstrating that your technical and professional competence is relevant and up-to-date.
Therefore the IAB has established this set of guidelines to help members appreciate what is required of them:
The IAB has developed a spreadsheet that can be used to record CPD, as members in practice are required to provide this to the IAB at the point of applying for or renewing a practicing certificate.
Download the spreadsheet to your PC using the following link:
Practice Example documents
Professional Indemnity Insurance
PII is available from various specialist organisations, but members of the IAB have access to a preferential PII scheme, details of which can be found using the following link:
If you are ceasing your self-employed bookkeeping business it is recommended that you continue your professional indemnity insurance for a period of time after stopping practicing to cover you for the possibility that a client may make a retrospective claim. This is known as ‘run off’ insurance. The period of time ‘run off’ insurance is taken out will depend upon the nature of your business, the number of clients you had and the risk that a retrospective claim may take place.
The Anti-Money Laundering Compliance Company (AMLCC)
- Training for all staff members to help them become acquainted with, and stay up-to-date with any changes in the AML regulation
- Client risk assessments
- Equifax checks
- Storage of all client details, copies of ID etc.
The AMLCC system is free to use for all IAB members in practice (with the exception of Equifax checks). Access to the system will be given once the initial application for a practicing certificate has been accepted. This process can take up to 7 days from the point the initial application.
Use the following link for instructions on registering with AMLCC:
For Accountancy Service Providers the requirements are set out in Regulation 26 of the MLRs. This stops a person with criminal convictions who is listed in Schedule 3 of the regulations from being a sole proprietor, manager, officer or beneficial owner.
In line with the other supervisors, as a member in practice you will be required to have a DBS check when you renew or apply for your practising certificate or certificate of AML supervision. You will need to make an application for a DBS check before we can issue you with your practising certificate.
Once you have had the DBS check we will only be able to continue to supervise those members who do not have a relevant criminal conviction.
Please find below some FAQs and the action which you will need to take in relation to this.
ACTION TO TAKE:
When you apply for or renew your practising certificate or certificate of AML supervision there will be a question asking whether you have made an application for a DBS check. We are only asking members to have the DBS check once and if you are currently supervised by the IAB you don’t need to do this until your supervision is due for renewal.
You can make the application through the government website. The system will automatically verify your ID and carry out the DBS check. Once the check has been completed you will then receive confirmation which you would then need to send to us when you renew your practising certificate or certificate of AML supervision so that we can update our records.
To make the application for a basic DBS check via the Government website please click on the relevant link below:
If you live in England or Wales please see: https://www.gov.uk/request-copy-criminal-record
If you live in Scotland please see: https://www.mygov.scot/basic-disclosure/apply-for-basic-disclosure/
If you live in Northern Ireland please see: https://www.nidirect.gov.uk/campaigns/accessni-criminal-record-checks
If I have previously had a DBS check do I still need to have another check carried out?
If you have had a DBS check carried out in the past 12 months then you will not need to have another check. You will just need to provide us with a copy of the document confirming that you have had a DBS check.
How often does the DBS check need to be carried out?
We only require members to have the DBS check once so you won’t have to renew it each year, unless there are any changes. Moving forward the DBS check will need to be completed when you renew or apply for your practising certificate or certificate of AML supervision on or after the 26th June.
If I only have a small handful of clients will I still need to have a DBS check?
Yes, no matter how many clients you have you will still need to have a DBS check. The regulations state that any sole proprietor, manager, officer or beneficial owner will need to go through this process.
What is a relevant criminal conviction?
The main concern is relating to serious convictions such as fraud. For instance if the DBS check uncovered a criminal conviction for fraud then we would no longer be able to issue you with a practising certificate or certificate of AML supervision and therefore, legally you would not be allowed to operate as a sole trader, officer, manager or beneficial owner of a company. It is also likely that you would no longer be able to be a professional member with the IAB.
What is the definition of a beneficial owner, manager or officer?
An officer includes someone who is a director, secretary or partner. Further information can be found here: regulation 3.
A manager is the Money Laundering Reporting Officer (MLRO) of a practice.
What do I need to do if there are other people working in my practice as officers, managers or beneficial owners?
Under the new rules all officers, managers and beneficial owners in your practice will need to have a DBS check. Please note the IAB does not need to see copies of the DBS checks for anyone else working in your practice. We only need to see a copy of your DBS check as a member in practice.
Application forms for practising certificate
If you are an overseas member looking to apply please contact the compliance department before completing the forms. Please email email@example.com.
Application for exemption
If this is the case, please complete the form below and send it with a copy of your practising certificate to the IAB for review.
Please note that having AML supervision with HMRC does not exempt you from holding a practising certificate with the IAB. If you currently have AML supervision with HMRC you must:
- Apply for a practising certificate with the IAB
- send a copy of your HMRC certificate with the form
- not renew your supervision certificate with HMRC when it expires
You will be given an extension to your IAB practising certificate that will run for one year after the expiration of your HMRC certificate.
For further information on IAB compliance please contact the Compliance Department on firstname.lastname@example.org or 01732 897756.