April 2017

Barristers and Accountants AML/ATF Board

Dear Ladies and Gentlemen,

I am pleased to be able to welcome George Jones and Heather VanSickle to the Board to help with the supervisory process. Heather has been appointed by the CPA and works as an Accountant and in Compliance for Meritus Trust. George has been appointed by the Bar Association and is the General Counsel at Argus Insurance. I look forward to new input and assistance on the Board.

Risk Assessments Due

Late last year we asked the sector to provide us with a copy of your Risk Assessments. Some have provided very good well thought out Assessments that the Board can use to begin to fully assess the risks of the sector as a whole . Generally however we believe work is needed in this area where Risks of your enterprises are fully considered and the Controls around those risks fully set out so that our Supervisor can check that the Controls are in place and are working. Also we need more engagement from the sector to get more robust data points in order to show Effectiveness as a Supervisory Authority. We will work hard to move the dial in this area because from these Risk Assessments the Compliance effort of the firms emanates and upon which the Compliance effort of the Board is based. Please send in your well considered Risk Assessments. We will also come back to the sector to seek data on the actual risks in your businesses as well.

2016 Data Due

We have started to collect data from the RPFs to start to measure our Effectiveness as a supervisory authority. Your feedback and input to this data gathering is most important as our Effectiveness will be measured over a period of time. We sent out a second questionnaire to the sectors to gather 2016 data. Please return your questionnaires otherwise we will have to resort to seeking Supreme Court rulings to force the delivery of the data.


The Supervisor is planning quarterly training session with the sector on topics that will assist you in better monitoring AML and ATF Risks. We will look to talk more about Risk Assessments, the importance of reporting SARs , the need to be very diligent when taking on PEPs as Clients and the need for engagement from the sector in the provision of information to the Board. We urge you to attend these sessions.

If you have questions or comments we ask you to contact us so that we can understand and respond to the needs and questions of the sector.


Christine Patton - Chairman