Anti-money laundering: Your 2022/23 AML renewal form

Members currently supervised by CIOT/ATT for anti-money laundering (AML) supervision should receive an email reminder to renew at the beginning of May when the 2022/23 AML renewal form goes live. Here are our top 10 tips to help you complete this year’s form:

1. The renewal form can be accessed at pilot-portal.tax.org.uk. You can use this link if you don't have your email.

2. The form works best if accessed through the following browsers:

• Microsoft Edge v86 or higher
• Google Chrome v86 or higher

Members have previously experienced problems using Firefox and Internet Explorer so these browsers are best avoided.

3. Your renewal form must be completed by midnight on 31 May 2022.

4. It is a legal obligation under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, to be supervised for AML at all times. If you fail to renew on time, you will be referred to the Taxation Disciplinary Board for a fine/disciplinary action.

5. The cost of supervision for 2022/23 has not increased and remains at £310.

6. At Q.31, you are asked: ‘Do you check HM Treasury’s Financial Sanctions consolidated list of targets and the Home Office’s Proscribed terrorist groups or organisations list as part of your client due diligence procedures to ensure you are allowed to act for a client?’ This is particularly important this year, given the situation with Russia and Ukraine. Further information can be found at:
www.tax.org.uk/new-financial-sanctions-in-relation-to-russia
www.att.org.uk/new-financial-sanctions-relation-russia

7. For sole practitioners, on questions that relate to ‘all staff and principals’, you should include yourself as a principal in your response (except for Q.35 which relates to communicating policies and procedures to staff where you can put ‘N/A’).

8. You do not need to repeat criminality checks for existing beneficial owners, officers and managers (BOOMs) but you do need to carry out criminality checks for any additional BOOMs appointed on or after 1 June 2021 and email the results to us separately at: aml@tax.org.uk.

9. When putting the number of BOOMs on Q.47 of your form, remember to include yourself.

10. There is an opportunity at the end for you to make sure you review and edit your form before it is submitted. This is helpful if completing the form via your phone, as experience has shown that it is easy to hit the wrong button and give an erroneous non-compliant answer.