Commentary

A7.116 Money Laundering Regulations—risk assessment

Administration and compliance

A7.116 Money Laundering Regulations—risk assessment

A7.116 Money Laundering Regulations—risk      assessment

The 2017 Regulations provide for a      'risk-based approach', including risk assessments to be conducted      by:

  1.  

    •     the Treasury and Home Office (a 'national risk      assessment') (regulation 16)

  2.  

    •     supervisory authorities (regulation 17), and

  3.  

    •     relevant persons (regulation 18)

HMRC has published new Money laundering guidance1 to help accountancy service      providers (ASP) recognise and reduce the risk of money laundering.

The guidance identifies the key areas that ASPs should consider as they      carry out supervised business activities. HMRC expects ASPs to carefully assess      and document the specific risks they face. They must establish policies,      controls and procedures to address these risks and review them regularly to help      prevent money laundering or terrorist financing.

National risk assessment

Under regulation 16, the Treasury and Home Office are required to prepare      a national risk assessment. The 2017 national risk assessment was published on      26 October 2017 and stated that:

'The 2015 NRA highlighted fraud and tax offences as the largest known      source of criminal proceeds from offending in the UK…The estimated      tax gap for evasion in 2014/15 was £5.2 billion. The tax and duty      regimes are also subject to criminal attacks including the coordinated and      systematic smuggling of

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