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At-A-Glance
Money laundering continues to be a significant concern with constituencies throughout the world. The Financial Action Task Force (FATF) was formed in 1989 by the G7 countries to tackle the problem and provide guidance. The FATF 2024 follow-up report is highlighted in this issue of the Audit & Accounting Alert, along with Great Britain’s recent National Risk Assessment of money laundering and terrorist financing 2025 (NRA).
Also, our Worldwide Update covers news from organizations across the globe.
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Money Laundering National Risk Assessment
Progress and continuing threats
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The May 2017 issue of the Audit & Accounting Alert included an article titled The Dark World of Money Laundering, where the Financial Action Task Force (FATF), the global body formed by the Group of Seven (G7) countries to address money laundering, was noted to criticize the United States for not implementing the FATF guidance for addressing money laundering. The FATF’s December 2016 report stated that “The United States has a well-developed and robust anti-money laundering and counter-terrorist financing (AML/CFT) regime through which it is effectively investigating and prosecuting money laundering and terrorist financing. However, the system has serious gaps that impede timely access to beneficial ownership information.”
The FATF issued its 7th Enhanced Follow-Up Report, Anti-money laundering and counter-terrorist financing measures – United States, in March 2024. The report focuses on forty categories for consideration. The United States was found to be in technical compliance (C) with nine of the categories, largely compliant (LC) with twenty-three, partially compliant (PC) with five, and non-compliant (NC) with three. These results represent a slight improvement with the LC category gaining two, while the PC and NC each lost one, compared to the 2016 report. The three areas of non-compliance are:
1. Customer due diligence by Designated Non-Financial Business and Professions (DNFBPs).
2. Regulation and supervision of DNFBPs.
3. Other measures concerning DNFBPs.
DNFBPs generally include attorneys, accountants, real estate agents, trust companies, precious metal dealers, and casinos. The non-compliant areas indicate inadequacies in checking out potential clients/customers, oversight of AML/CFT issues and activities in foreign countries.
The earlier A & A Alert also described the United Kingdom’s efforts as enumerated in the October 2016 Manifesto for Fighting Economic Crime, published by a group of UK accounting bodies. Now in its fourth rendition, National risk assessment of money laundering and terrorist financing 2025, has been published on July 17, 2025.
The purpose of the National Risk Assessment (NRA) is to:
1. Consolidate the “collective knowledge of money laundering and terrorist financing risks.”
2. “Identify, assess, understand, and mitigate the risks of money laundering and terrorist financing affecting the United Kingdom,” and ensure appropriate resources to counter.
3. Direct regulated firms to conduct risk assessments and take steps to lessen risks.
4. Function along with System Prioritisation, which will publish a list of economic crime priorities.
After a general discussion of money laundering, the NRA specifically addresses the following threats:
- Fraud
- Sanctions Evasion
- Acquisitive Crime
- Drugs
- Cyber Crime
- Organised Immigration Crime
- Tax Evasion
- Modern Slavery and Human Trafficking
- Online Child Sexual Exploitation and Abuse
- Environmental
- Bribery and Corruption
The forms of money laundering are described in the following categories:
- Cash
- Informal Value Transfer Systems
- Cryptoassets
- Trade-Based Money Laundering
- Property
- Companies and Trusts
- Professional Enablers
Then after a section on terrorist financing, a detailed discussion of these specific industries is covered:
- Retail Banking
- Wholesale Banking and Markets
- Wealth Management
- Insurance
- Electronic Money Institutions and Payment Service Providers
- Cryptoasset Service Providers
- Money Service Businesses
- High Value Dealers
- Art Market Participants
- Casinos
- Non-Profit Organisations
- Legal Service Providers
- Accountancy Service Providers
- Trust or Company Service Providers
- Estate Agency Businesses
- Letting Agency Businesses
- Artificial Intelligence
- Schools and Universities
- Football Clubs and Football Agents
Further details can be found at Anti-money laundering and counter-terrorist financing measures - United States and National risk assessment of money laundering and terrorist financing 2025.
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Worldwide Update
Periodic roundup of recent and upcoming actions and activities by auditing and accounting organizations throughout the world.
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International
IASB – International Accounting Standards Board (www.ifrs.org)
- Targeted Improvements to the Accounting for Internal-Use Software ASU 2025-06, issued September 18, 2025, “addresses changes in software development methods, increasing the operability of the recognition guidance for improved financial reporting.” Effective for all entities for annual reporting periods beginning after December 15, 2027, and interim reporting periods within those annual reporting periods. Early adoption is permitted as of the beginning of an annual reporting period.
- Derivatives Scope Refinements and Scope Clarification for Share-Based Noncash Consideration from a Customer in a Revenue Contract – ASU 2025-07 - An Amendment of the FASB Accounting Standards Codification, issued September 29, 2025, to “that addresses stakeholders’ concerns about (1) the application of derivative accounting to contracts with features based on the operations or activities of one of the parties to the contract and (2) the diversity in accounting for share-based noncash consideration from a customer that is consideration for the transfer of goods or services.” Effective for all entities for annual reporting periods beginning after December 15, 2026, and interim reporting periods within those annual reporting periods. Early adoption is permitted.
- Exposure Draft - Initial Measurement of Paid-in-Kind Dividends on Equity-Classified Preferred Stock, issued September 30, 2025, “to provide authoritative guidance on how an issuer should initially measure paid-in-kind (PIK) dividends on equity-classified preferred stock.” The comment period ends on October 27, 2025.
IFAC – International Federation of Accountants (www.ifac.org)
- International Public Sector Financial Accountability Index, issued September 23, 2025, “collects, verifies, and analyzes current financial reporting bases and frameworks used by federal and central governments around the world. It also provides an overview of public sector reporting trends.”
IFR4NPO - International Financial Reporting for Non-Profit Organisations (www.ifr4npo.org)
- New foundation to drive non-profit transparency globally, reported on October 1, 2025. The Chartered Institute of Public Finance and Accountancy (CIPFA), “will provide the long-term home for the International Non-Profit Accounting Standard (INPAS), a first-of-its-kind comprehensive accounting framework.”
IOSCO – International Organization of Securities Commissions (www.iosco.org)
ACCA – Association of Chartered Certified Accountants (www.accaglobal.com)
- Internal control over sustainability data, reported released on October 7, 2025, “reveals that there is a real opportunity for accountancy, finance and internal audit professionals to drive the sustainability agenda by applying internal control principles to sustainability-related data.”
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Africa, Europe, India and the Middle East (AEIME)
FRC – Financial Reporting Council of the UK (www.frc.org.uk)
- ISA (UK) 240 - The Auditor's Responsibilities Relating to Fraud in an Audit of Financial Statements, and ISA (UK) 570 - Going Concern, consultation published October 1, 2025. “Revisions to ISA 240 clarify auditors' responsibilities regarding fraud detection, strengthen risk assessment procedures, and enhance transparency in audit reports—particularly for publicly traded entities. Meanwhile, updates to ISA 570 improve how auditors evaluate whether companies can continue operating, following corporate failures that have damaged public confidence in auditing.” Consultation ends January 16, 2026.
ICAEW - Institute of Chartered Accountants in England and Wales (https://www.icaew.com/)
EC – European Commission (https://ec.europa.eu/)
EFRAG – European Financial Reporting Advisory Group (www.efrag.org)
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Americas, Asia, Australia and New Zealand (AAANZ)
AICPA & CIMA – American Institute of Certified Public Accountants (www.aicpa.org)
FASB – Financial Accounting Standards Board (www.fasb.org)
- Exposure Draft - Initial Measurement of Paid-in-Kind Dividends on Equity-Classified Preferred Stock, Proposed Accounting Standards Update Issued: September 30, 2025, to provide authoritative guidance on how an issuer should initially measure paid-in-kind (PIK) dividends on equity-classified preferred stock. Comments Due: October 27, 2025.
- ASU 2025-07 — Derivatives and Hedging (Topic 815) and Revenue from Contracts with Customers (Topic 606) - Derivatives Scope Refinements and Scope Clarification for Share-Based Noncash Consideration from a Customer in a Revenue Contract issued September 29, 2025, “addresses stakeholders’ concerns about (1) the application of derivative accounting to contracts with features based on the operations or activities of one of the parties to the contract and (2) the diversity in accounting for share-based noncash consideration from a customer that is consideration for the transfer of goods or services.” Effective for all entities for annual reporting periods beginning after December 15, 2026, and interim reporting periods within those annual reporting periods. Early adoption is permitted.
- ASU 2025-06 — Intangibles—Goodwill and Other— Internal-Use Software (Subtopic 350-40) - Targeted Improvements to the Accounting for Internal-Use Software, issued September 18, 2025, “updates the guidance on accounting for internal-use software costs” to “improve the operability of the guidance by removing all references to software development project stages so that the guidance is neutral to different software development methods, including methods that entities may use to develop software in the future.” Effective for all entities for annual reporting periods beginning after December 15, 2027, and interim reporting periods within those annual reporting periods. Early adoption is permitted as of the beginning of an annual reporting period.
GASB – Governmental Accounting Standards Board (www.gasb.org)
COSO - The Committee of Sponsoring Organizations of the Treadway Commission (www.coso.org)
PCAOB – Public Company Accounting Oversight Board (www.pcaob.org)
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Policy Statement Regarding Implementation of Paragraph .10A of AS 1105, Audit Evidence, PCAOB Release No. 2025-004, released September 18, 2025, stating “Paragraph .10A requires auditors to evaluate the reliability of external electronic information provided by the company by: (a) obtaining an understanding of the source and of the company’s process for receiving, maintaining, and processing the information; and (b) testing the information or the relevant controls. Paragraph .10A does not prescribe the nature, timing, or extent of procedures. Instead, the requirements are principles-based and scalable.”
SASB – Sustainability Accounting Standards Board (www.sasb.org)
SEC – Securities and Exchange Commission (www.sec.gov)
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Audit & Accounting Alert is a publication of Integra International intended to highlight emerging issues in the profession. The goal is to give Integra members an awareness of developments impacting the practice of Audit & Accounting enabling them to stay on the forefront of industry trends.This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice.
Editor Gerald E. Herter
www.Integra-International.net
© 2021 Integra International. All Rights Reserved.
If you wish to stop receiving email from us, you can simply remove yourself by visiting http://members.integra-international.net/members/EmailOptPreferences.aspx?id=66979517&e=lois.pares@integra-international.net&h=d523ac69369762eb987573d57c33e956f959035d.
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