Guidance and pro forma documents for use by small firms supervised by the ATT

The updated AMLGAS issued on 10th September 2020 awaits approval from HM Treasury. In the meantime, the ATT have updated the pro forma below based on the draft guidance. This will be reviewed whem HM Treasury approved guidance is issued. 

The ATT and CIOT have worked with the wider Accountancy AML Supervisors’ Group (AASG) to produce updated AML risk guidance. This has been adopted by the ATT and CIOT as their Supervisory Risk Assessment guidance for use by members. This April 2022 document is available here.

This should assist firms as they deal with the written risk assessment of their practice and the risk assessment of individual clients.

HMRC have also provided information relating to Understanding risks and taking action for Trust or Company Service Providers and members undertaking work of this nature may also find it helpful to refer to this document.

The current versions of the documents are available as follows:

These are required by all firms under MLR 2017 (as amended) regardless of size.  The documents will be most suitable for sole practitioner or small two partner/two director firms. 

These documents are requested when the ATT undertake AML supervision visits and may also be requested where random checks are undertaken to make sure that information provided by members on their registration forms is correct.  Failure to comply with these requests or if we find that you have given incorrect information on the form will result in a referral to the Taxation Disciplinary Board.