Creating a AML Compliance Programme: An Accountants Experience

By Marion Garlick, Director of Gilligan Sheppard


Thinking back to when legislation was first introduced, the task of understanding and implementing the requirements of the AML Act was a daunting concept. As is necessary, the consequences of not complying or simply getting it wrong, can result in serious reputational and financial costs.


With a sturdy compliance programme now in use, we can reflect on the process of creating our programme and the experience that came with it:


Step 1: Appoint a Compliance Officer


We assigned one of our Partners, Yi Ping, the task of preparing and implementing our risk assessment and compliance programme.


Step 2: Do Your Research


By attending courses and reading up on risk and compliance, we were able to gain adequate knowledge to create this programme.


An occurrence at some of these courses was the heated debate between accountants regarding compliance and the monetary cost to businesses.


This stemmed from legislation appearing as a ‘burden of extra compliance’ to some accounting practices and professionals, as many of them are small businesses and do not have an excess of human or financial resources and capital to spare on the cost of compliance.


Step 3: Stand Back and Appreciate the Positives


As we began to understand the intent of the legislation, this being based around the principle of knowing your client, we began to see some of the benefits that would come from implementing our compliance programme.


Having a greater understanding of who our client was, by knowing their background, family relationships, full names, dates of birth and current addresses, provides us with the information we need to be able to advise our clients and communicate with them. This is something we should do as part of our usual business practices, to gather this information in a concise and cohesive manner.


After the initial “OMG how do we do this?” we applied the “how do you eat an elephant?” approach, which is one bite at a time


Reap the Rewards


Having a greater understanding of who our client was, by knowing their background, family relationships, full names, dates of birth and current addresses, provides us with the information we need to be able to advise our clients and communicate with them. This is something we should do as part of our usual business practices, to gather this information in a concise and cohesive manner.


The process of implementing AML has provided us with an opportunity to update key information for our existing clients and improve our onboarding system for all new clients that not only meet the requirements of the AML legislation but helped us to better understand who our clients are.


In turn, the process has resulted in our clients learning more about us and the services we can provide for them.


Once we gather the information we need as a practice and identify what services the client requires, we then consider whether any of the services are “Captured Activities” and complete any additional checks to meet AML requirements.


Gilligan Sheppard Logo

Captured Activities for Our Practice


1. Acting as a formation agent for legal person