I am honoured to be invited by ISCA to speak at its 6th SMP Dialogue where I shared my thoughts on what small medium practitioners can do to overcome Ethics Pronouncement 200 (EP200) implementation challenges in respect of AML/CTF. The last time I spoke at the same event was in December 2015 (3rd SMP Dialogue).
This smacks right at the heart of what I have been saying about Designated Non-Financial Businesses and Professions (DNFBPs) needing to get serious on AML/CTF obligations. Accountants, as one category of DNFBPs, were singled out during the last Financial Action Task Force (FATF) Mutual Evaluation Review of Singapore in 2015.
Privileged to share the same stage with ACRA Inspection Team, ISCA Quality Assurance Team as well as several other SMPs and it was an "over-subscribed" event of close to 150 participants. Met a number of clients and ex-colleagues too.
EP200 was first issued in November 2014 and last amended in March 2017. I suggested some practical tips and steps on how SMPs can overcome some hurdles in their EP200 implementation process.
9 Steps to Nirvana
I figured that given the audience comprises largely Accountants (and me being an ex-Auditor), it probably makes sense to break up AML/CTF into steps and processes. Hopefully, that makes it easier for SMPs to understand. I call it 9 Steps to Nirvana!
4 Pillars of AML/CTF
Building a strong AML/CTF foundation is not easy but it is not impossible too even for SMPs. Breaking down EP200 requirements into my famous 4 Pillars of AML/CTF will make it easier to digest and implement. You can't do everything all at the same time but not getting started is definitely not getting you anywhere.
At the end of the day, SMPs have a regulatory obligation to comply with EP200. Given the recent amendments to Accountants Act, there is now "teeth" to the effects of EP200 and that ACRA/ISCA will be carrying out inspections on the industry.
As alluded to in the slide above, whilst SMPs need to have mechanism to ensure effectiveness of their own CDD measures, ACRA/ISCA equally have to demonstrate that EP200 and Accountants Act are effective too. Without inspection and assessment, there is no way this can be achieved. So sit tight and buckle up.
On a separate note, good to see a number of clients speaking on a panel sharing their collaborative approach to improve audit quality. A fantastic idea!
As the panel discussed teamwork, collaboration and trust amongst the 5 SMPs, one interesting point that was brought up on playing to each other's strengths and competencies reminded me that Compliance is also a rather lonely job. It is not easy to find reliable peers to bounce off advisory, training and monitoring approaches and ideas. Anyway, that's for another day.
For practitioners who have missed this very information session, ISCA has an upcoming event, Quality Assurance Seminar 2017 on 22 May (Mon) where ACRA will share further insights from their previous EP200 inspections on larger practitioners. Cynopsis is proud to be a sponsor for this upcoming event. Sign up here.