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ACCA Strategic Professional · Advanced Audit and Assurance (International) · Money laundering

Ferris & Partners is reviewing its anti-money laundering framework. Which firm-level arrangement is most clearly required to demonstrate that the firm complies with money laundering regulations and the ISQM 1 approach to quality management?

The firm needs a documented firm-wide risk assessment supported by policies, controls, training and record-keeping that address the identified risks. This mirrors the risk-based design of ISQM 1. Partner declarations, reliance on a client's policies or one-off due diligence do not provide adequate ongoing firm-level compliance.

  1. AA documented firm-wide risk assessment, with policies, controls, training and record-keeping that respond to the risks identifiedCorrect
  2. BA single annual declaration by partners that they know of no suspicious clients
  3. CReliance on the client's own anti-money laundering policies instead of firm policies
  4. DDue diligence performed only at the start of the relationship, with no later updates

Explanation

Regulations expect a firm-wide risk assessment feeding policies, controls, staff training, monitoring and record retention, which aligns with the risk-assessment-driven quality management system in ISQM 1. Annual declarations, reliance on client policies and one-off due diligence do not meet the requirement for ongoing, firm-owned controls.

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