Anti-money laundering whistleblowing
Whistleblowing is speaking up or raising a concern if someone sees something wrong or unethical taking place in the workplace, The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("the MLR") requires AAT, as a supervisor to take effective measures to encourage its own sector to report breaches of the provisions of the regulations to us as soon as there is a genuine concern.
If you believe a firm supervised by us is failing to adhere to the anti-money laundering (AML) requirements in force, for example not having any internal policies, controls, or procedures in place, or staff not being adequately trained in client due diligence procedures to spot red flags, or even suspicious client activity not being reported by the firm, you may report it confidentially to us. If the information is provided to us on a confidential basis, we will take the appropriate steps to protect your identity.
Please do not use this helpline if you suspect a client is involved in money laundering or terrorist financing. If you "know", "suspect" or have reasonable grounds for knowing or suspecting that an individual is engaged in money laundering or dealing in criminal property you have a duty to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) as soon as it is reasonably practicable. If you report it to AAT as your supervisory authority instead of the NCA this does not transfer any part of those responsibilities to us under the law. If it is identified you failed to alert law enforcement of any potential money laundering to terrorist financing, you will face prosecution.
How to report information to us
If you're unsure whether a firm is supervised by AAT, please check our Licensed Member Directory.
If they are, then to enable us to review your information as quickly as possible, please email aml.whistleblowing@aat.org.uk providing as much information as possible, including:
- the names of any individuals and/or firms involved
- details of the alleged violation of a law, rule or regulation
- any key dates
- details of any internal procedures followed and the outcomes
- a summary of the supporting evidence you have provided – is it known and substantiated?
On receipt, your disclosure will be considered in accordance with the Anti-money laundering whistleblowing policy (PDF) to determine what action is to be taken.
Alternatively, you can call on +44 (0)20 7397 3182 to discuss, in confidence, your concerns about an AAT member or an AAT supervised firm.
How we'll use the disclosure
Depending on the information provided, we may take different types of action in response, including:
- keeping the complaint on record and monitoring the firm closely
- deciding a practice assurance review visit should take place
- making a confidential report to law enforcement agencies
- using the information as part of a formal investigation into a firm.
If a concern you've raised turns out to be unfounded when investigated further this doesn't mean that you shouldn't have raised it in the first place.
How we'll keep you informed
We'll write to confirm receipt of your information and may contact you again if we require anything further from you, unless you specifically ask us not to.
Firms not supervised by AAT
If you identify an accounting service provider or trust and company service provider that doesn't appear to be supervised under the Money Laundering Regulations, or disregarding the requirements of the regulations, you can contact:
- the firm's relevant supervisory body
- the MLR Central Intervention Team at MLRCIT@hmrc.gov.uk.
These contact details are solely for the purpose of reporting matters relating to possible breaches of the Money Laundering Regulations. They are not to be used in relation to general complaints or queries regarding the professional conduct of AAT members. Any matters of this nature should be reported via the AAT complaints process.
Other helplines available
There are several other helplines available to AAT members which may provide practical advice for a range of scenarios. The general procedure is to ask for your name and membership number but you're welcome to remain anonymous should you wish to do so. Please note that any guidance is based on information you provide us and may not be treated as legal advice or a formal ruling.
Protect – Speak up, Stop Harm
Protect (formerly Public Concern at Work) are leading experts in whistleblowing. They operate a free, confidential advice line.
For whistleblowing advice you can call +44 (0)20 3117 2520, email whistle@protect-advice.org.uk or visit their website.
Useful guides and publications
