This guidance is aimed at practitioners in the accountancy profession countries and their competent authorities, practitioners in the banking sector, and other financial and designated non-financial sectors that rely on the customer due diligence performed by accountants.The guidance aims to support accounting professionals in the design of effective measures to manage their ML/TF risks, when establishing or maintaining business relationships. The risk-based approach is central to the effective implementation of the FATF Recommendations to fight money laundering and terrorist financing. This guidance highlights the need for a sound assessment of the ML/TF risks that accountants face so that the policies, procedures and ongoing CDD measures mitigate these risks. The accounting sector must meet customer due diligence and record-keeping requirements when, on behalf of their client, they are involved in real estate transactions managing money, securities or other assets managing bank, savings or securities accounts creating, operating or managing companies, or legal persons and arrangements and buying and selling business entities. Accounting and related auditing firms must therefore protect themselves from misuse by criminals and terrorists. For example, professional money launderers have been known to keep a shadow accounting system with records of transactions involving proceeds of crime. Recent FATF research highlighted examples of accountants that had used their occupation, business infrastructure and knowledge to facilitate money laundering for criminal clients. The legally required services that accountants provide make them vulnerable to become unwittingly involved or accessory to money laundering or terrorist financing activities. The accounting profession is a diverse sector with accountants that vary substantially in the breadth and nature of services they provide, the clients they serve and the size and level of sophistication of the firm and its employees.
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