The National Board of Accountants and Auditors (NBAA) has a duty to make sure that its members throughout the country comply with relevant laws, regulations and guidelines. NBAA for the first time in January 2010, issued the Anti-Money Laundering Guidelines for Accountants and Auditors in collaboration with Financial Intelligence Unit (FIU) to assist its members to comply with the requirements of the Anti-Money Laundering Act (AMLA), 2006 (CAP. 423) and its regulations.

The NBAA in conformity with time to time changes of AML/CFT legislations has seen the need to revise the above said Guidelines so as effectively to assist members to implement their legal obligations.

Accountants and auditors being reporting persons under Section 3 of the AMLA are obliged to carry out customer due diligence, maintain records, report suspicious transactions and maintain internal reporting procedures aimed to detect and prevent money laundering and financing of terrorism (ML/TF) activities. In addition, they are required to facilitate the investigation and prosecution of money laundering and terrorist financing offences.

The revised Guidelines provide members with more details on the requirements of the Prevention of Terrorism Act (POTA), CAP 19, Cash Transaction Report Regulations and considerations of the National ML/TF Risk Assessment conducted in 2016, which encourage the application of risk based approach.

The revised Guidelines have included case studies on fighting money laundering, terrorist financing and economic crime in order to provide some practical guidance to members and the lesson to be learned from those case studies. The case studies have been used only for the purpose of illustrating red flags which members should pick up to identify suspicious activity.

The NBAA appeals to all members of the Accountancy Profession to regularly read and comply with the procedures provided in these guidelines. It is personal responsibility for Accountants and Auditors to observe regulatory framework of AML/CFT regime at several points in the whole process of professional practicing when dealing with individual, entity or third party.

The Guideline is also freely available for download by clicking this link.