AMLCC is a web-based platform that brings together the full range of tools needed to achieve Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) compliance and risk management. AMLCC is designed for any firm that works as an Accountancy Service Provider (defined to include accountancy, bookkeeping, tax, insolvency and auditing).
Your firm’s AML/CTF steps can be recorded within AMLCC and stored securely online. There’s no need for you to update or download software.
Editable template for your firm policy (including your firm’s services)
Your firm’s AML policy is the base for your firm’s AML compliance. Your draft firm’s policy is in an easy to use text-editable format. Simply alter the policy to reflect how your firm operates. Your firm details and firm services are automatically added to the policy. A history of earlier versions is included along with an audit trail.
You can view your policy within the system or download a PDF version. Your firm policy is set by the person responsible for the AML compliance within your firm (if you work on your own then that’s you!).
Each member of your team will be asked to acknowledge that they have read and understood the policy, and this is then recorded within AMLCC.
The template firm policy includes more educational content to add to the two training videos within AMLCC.
Firm risk assessment (including guidance and mitigation steps)
Your firm’s risk assessment is a record of the AML risks that your firm is exposed to. The firm risk assessment questions are set within the system and the answers are selected by the firm. Guidance and suggested mitigation steps are included alongside the questions to assist you with completing the risk assessment.
Any documents that help provide additional depth to your risk assessment can be uploaded to each question. These can then be managed through the document management system and comments can be added to each answer to further match your firm’s requirements.
The risk mitigation function allows the question risk outcome to be reduced from high risk to risk mitigated. This requires senior management approval.
A PDF report of the risk assessment is available to download or can be viewed.
Client risk assessments (including guidance and mitigation steps)
Different client risk assessments are included on the system. You’ll need to select your client type and complete the risk assessment accordingly. The functionality of these risk assessments is the same as the firm risk assessment with guidance and mitigation steps included, along with document upload and add comment functionality.
Risk mitigation is also available to reduce the risk status of a question and if all high-risk answers are risk mitigated; the client risk profile is reduced. An audit trail of changes is stored for each client.
Where a client’s circumstance requires that Enhanced Due Diligence (EDD) be undertaken then completion of additional EDD questions will be requested to ensure proper steps are taken by your firm.
An annual reminder is provided to review each client risk assessment. Beneficial owners of incorporated entities can be linked to a client.
For an additional annual cost, it is possible to use the saveable bespoke template feature. These enable you to save a set of template answers for similar clients and then adjust them where necessary to ensure that they are client specific.
This is a useful time-saving feature if you have several, similar clients. Saveable bespoke templates are set by client type and any one template can be used multiple times for similar clients for the cost of one annual template.
The client dashboard shows the status of all of your clients in one place. You can click on the different sections to drill down again to view the clients within each of the status categories.
There is no limit for the number of clients that you can use on AMLCC.
Beneficial owners of incorporated entities can be linked to a client.
You can upload client lists using the import template which can be found under the “upload clients” feature within the Client Records section. The template also allows you to use your own client references for when you import the data into AMLCC.
Once your clients have been entered on to the system you are then able to generate company credit reports using a Pay As You Go service.
The system allows you to archive clients when you are no longer engaged with them and it also allows you to archive staff if they leave the firm. The archive functionality allows records to be kept intact without clogging up current lists.
You can link incorporated entities to their beneficial owners within the system and once the beneficial owners are added, you can then generate an Equifax online client verification report using the Pay As You Go service. You can buy as many or as few credits as you like, and the best part is that they don’t expire! The credits last as long as you subscribe to the system.
Clients can be allocated to staff members. View UK Companies House data on limited companies; company number if needed.
Document Storage and Management
You can upload documents to attach to specific risk assessment questions for both the firm and for the client risk assessments. You can also upload and attach documents to the client details page. Details such as upload date, expiry date and reminder date are stored with the uploaded documents.
The system also allows you to set your own expiry and reminder dates for events such as when a clients’ ID expires or when a year has passed since you last ran a client verification.
The document dashboard includes search functions on a variety of criteria.
Firm Wide Training
The system provides training videos with accompanying slides for all staff and an additional video for senior management. All staff need to complete the multiple-choice test which can be found in the training area. The test needs to be completed to ensure that the information from the video has been understood and absorbed. A log of all staff that have watched the videos and taken the tests is kept within the system.
Additional training is included within the firm policy and within the guidance and mitigation steps that are contained within the firm and client risk assessments.
Related blogs and news articles are regularly added to the system to provide updates and useful information to users.
Internal Suspicious Activity Reporting
The firm’s staff can report suspicious activity through AMLCC directly to the firm’s MLRO. The MLRO can then consider the next steps in light of the report and if necessary, visit the National Crime Agency (NCA) website to submit a report.
Online Downloadable Manual
AMLCC provides a comprehensive AML manual which is available for you to download directly from the website. The manual is split into different chapters and appendices and is available in either a PDF or Microsoft Word format. The Word version of the documents can be edited for your firm’s needs.
The manual provides useful forms that can help to fill any gaps your firm’s paper-based procedures.
Make AMLCC Suit Your Practice Needs
By adding and editing comments, choosing your firm services, uploading documents and editing your firm policy you are carrying out the key steps required to ensure that AMLCC accurately reflects what your firm does as a practice and the range of clients that you work for.
You can make use of aspects of the online manual to fill any gaps in your firm’s procedures.
Allow Access to Review AMLCC to Authorised Third-Parties
Your firm can grant read-only short-term access to third parties to review your firm’s compliance.