Alan Paterson
Asad Choudhary
John Pool
Advisory and Transformation
AML/CTF/CPFDesignated Non-Financial Businesses and Professions (“DNFBPs”) are businesses that are considered to pose a money laundering risk but cannot be classified as a financial institution. They are seen as ‘gatekeepers’ to the financial system and include professions such as accountants, lawyers, estate agencies, casinos, high value dealers, and trust or company service providers.
In the UK, these professions are subject to the requirements of the Money Regulations 2017. Each industry’s regulatory oversight bodies (e.g. Solicitors Regulation Authority, Institute of Chartered Accountants in England and Wales, Chartered Institute of Management Accountants) are required to act as Anti-Money Laundering supervisors.
The 22 professional bodies overseeing the legal and accountancy sectors in the UK are, in turn, overseen by the Office for Professional Body Anti-Money Laundering Supervision (OPBAS), a regulator housed within the FCA and charged with strengthening the UK’s Anti-Money Laundering supervisory regime and ensuring that professional body AML supervisors provide consistently high standards of AML supervision.
Conclusion
In order to ensure compliance with the Money Laundering Regulations 2017, DNFBPs must ensure that they have a robust financial crime control framework in place. We would typically recommend an assessment to evaluate the effectiveness of the financial crime framework and controls with reference to UK laws and regulatory requirements, which can typically be conducted in a 2-3 week timeframe. This will help to identify any deficiencies and will result in a set of recommendations to meet regulatory requirements.
