Laura WilesThe FCA has censured the Institute of Certified Bookkeepers (ICB) for serious deficiencies in its AML supervision.
The action is the FCA’s first ever enforcement outcome against a professional body supervisor (PBS), and comes after the announcement in October that the FCA is set to become the sole AML supervisor for professional services firms, replacing PBSs in the legal and accountancy sectors.
Under the MLRs, ICB is currently responsible for overseeing the AML compliance of several thousand bookkeepers.
Between January 2022 and July 2023, ICB breached key regulations governing its role as supervisor. In particular, it had failed to maintain an adequate risk-based approach to supervision and to effectively monitor its members. It made these significant breaches worse by suspending all onsite and virtual inspections for 9 months, thereby seriously undermining its own ability to assess members’ AML compliance. The FCA’s enforcement notice highlights that ICB did not presented any supporting documentation for its decision to suspend investigations, and has no written record setting out a reasoned explanation for this decision, despite consensus internally that inspections were a crucial part of its supervision. Broadly, the FCA also identified a lack of clear record-keeping across the organisation.
Since these issues were identified, ICB has engaged constructively with OPBAS and provided evidence to the FCA showing that it has significantly improved its staff understanding of AML procedures.
The FCA considered that public censure was the appropriate action in this case, and does not have the power to impose financial penalties on ICB as an OPBAS supervised entity.