Risk-based approach guidance: legal professionals, accountants, Trust and Company Service Providers

AAT welcomes any improvements in information and guidance available to the various relevant professional sectors, to help them be both compliant and proactive in their anti-money laundering activities.

The guidance being consulted upon is comprehensive and clear; it reflects and builds on previous FATF reports and guidance, as well as those produced by UK bodies such as the FCA and OPBAS.

That said, AAT does have one observation about the continued reference to simplified client due diligence. Considering that the sectors for which this guidance has been produced have all been rated as high risk, it would seem logical that all due diligence should be at the current Standard level as a minimum, to avoid any confusion and prevent any dilution of compliance levels.