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Fyling
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AML records and risk assessments

What Fyling does and does not do

Fyling keeps your records: the practice risk assessment, a risk assessment and due diligence record for each client, sanctions screening results, and what you record about politically exposed persons.

Fyling does not check identity documents, does not run a PEP database check, and does not decide whether a client is acceptable. Those judgements, and the duty to act on them, are yours and your MLRO's.

Where the duty comes from

Accountancy practices must follow the Money Laundering Regulations 2017. They must assess the risk of money laundering in the practice, and check each client in proportion to their risk, under the supervision of a body such as ICAEW, ACCA or HMRC.

Source: gov.uk: Money Laundering Regulations

In the order the app asks

  1. Practice risk assessment. Write down how money laundering could happen through your practice and keep it up to date. Only an owner can approve it.
  2. AML settings. Set how your practice scores risk by client type and by where the client is based. The score is a guide, not the assessment.
  3. Client risk assessment. From the AML client list, answer the questions before you start due diligence. Each save is kept as a new record of what you knew at the time.
  4. Due diligence. Record the checks you did on the client and the evidence you saw. Fyling keeps the record.
  5. Sanctions screening. Your clients, and the directors and PSCs of the companies they own, are screened against the UK Sanctions List. A possible match is a reason to look closer, not a finding.
  6. PEP statements. A politically exposed person holds, or recently held, a prominent public role. Record what you know about the client and the people who own or run it.
  7. Ongoing monitoring. Record things you learn that may change a client's risk under Changes. The client list shows who is due a review, soonest first.

Source: gov.uk: UK sanctions list

Your own duties

The practice page shows your supervisor, your MLRO, and when you last reviewed your policies. A staff training page records who has been trained and when it is next due. Anyone in the practice can report a concern to the MLRO from Internal reports.

Moving from another system

You can import risk ratings and due diligence dates from your old system so review dates are not lost, and export your records when an inspector asks for them.

What it does for your practice: AML and client due diligence