Anti-money laundering whistleblowing
Whistleblowing is speaking up or raising a concern. If someone sees something wrong or unethical taking place in the workplace, they must be able to raise this within their organisation or to a regulator if appropriate.
If you identify an accountancy firm that is supervised by AAT and appears to be failing to adhere to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, you can report it confidentially to us. If information is provided to us on a confidential basis, we will take the appropriate steps to protect your identity. AAT strongly encourages both our members and members of the public to raise matters as soon as there is a genuine concern, in accordance with the procedure set out below.
How to report information to us
To enable us to review your information as quickly as possible, please email email@example.com providing as much information as possible, including:
- the names of any individuals and/or firms involved
- details of the alleged violation of a law, rule or regulation
- any key dates
- details of any internal procedures followed and the outcomes
- a summary of the supporting evidence you have provided – is it known and substantiated?
If you are not able to email the documents, please send your written enquiry and documentary evidence to:
30 Churchill Place
London, E14 5RE
On receipt, your disclosure will be allocated to an appropriate investigating officer in the Professional Standards team, who will then carry out an assessment in accordance with the Anti-money laundering whistleblowing policy (PDF) to determine whether there are grounds for action to be taken. It may be that a concern you've raised turns out to be unfounded when investigated further but this doesn't mean that you shouldn't have raised it in the first place.
Alternatively, you can call on +44 (0)20 7397 3182 to discuss, in confidence, your concerns about an AAT member or an AAT supervised firm.
How we'll use the disclosure
Depending on the information provided, we may take different types of action in response, including:
- keeping the complaint on record and monitoring the firm closely
- deciding a practice assurance review visit should take place
- making a confidential report to law enforcement agencies
- using the information as part of a formal investigation into a firm.
How we'll keep you informed
We'll write to confirm receipt of your information and may contact you again if we require anything further from you, unless you specifically ask us not to.
Firms not supervised by AAT
If you identify an accounting service provider or trust and company service provider that doesn't appear to be supervised under the Money Laundering Regulations, or disregarding the requirements of the regulations, you can contact:
- the firm's relevant supervisory body
- the MLR Central Intervention Team at MLRCIT@hmrc.gov.uk.
These contact details are solely for the purpose of reporting matters relating to possible breaches of the Money Laundering Regulations. They are not to be used in relation to general complaints or queries regarding the professional conduct of AAT members. Any matters of this nature should be reported via the AAT complaints process.
Other helplines available
There are several other helplines available to AAT members which may provide practical advice for a range of scenarios. The general procedure is to ask for your name and membership number but you're welcome to remain anonymous should you wish to do so. Please note that any guidance is based on information you provide us and may not be treated as legal advice or a formal ruling.
Protect – Speak up, Stop Harm
Protect (formerly Public Concern at Work) are leading experts in whistleblowing. They operate a free, confidential advice line.