We welcome AMLA’s risk-based approach to ongoing monitoring under the EU Anti-Money Laundering Regulation (AMLR), while calling for greater proportionality and clarity for small- and medium-sized practices (SMPs). It welcomes the recognition that monitoring may be manual, automated or semi-automated, provided it is explainable, documented and proportionate.
As well we stress that expectations designed for banks should not be applied to SMPs. Accountants, auditors and tax advisers often do not control or continuously observe client transactions; their monitoring should therefore rely on engagement-level information, professional judgement and relevant information obtained through the professional relationship.
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