Quality management and AML / CTF documentation

SQM / AML Consultancy Services

Practical, customised compliance documentation for CPA practices that need to demonstrate a working System of Quality Management and AML / CTF framework—not simply hold a generic template.

EQC SQM and AML Consultancy Services brochure cover

Compliance Frameworks Designed Around Your Practice

EQC’s SQM and AML Consultancy Services support the design and implementation of quality-management and anti-money-laundering compliance frameworks tailored to each practice’s operational structure, client profile, and risk environment. The work is intended to help internal controls meet current regulatory expectations while supporting workable day-to-day processes.

Every practice’s quality risks are different. EQC combines familiarity with AFRC inspection processes and practical CPA-practice experience to develop documentation that goes beyond a generic template, helping turn compliance requirements into a source of operational discipline, client confidence, and professional assurance.

Download the SQM / AML Consultancy Brochure

What Is SQM and Why Does It Need to Be Customised?

New and clarified auditing standards, changes in accounting frameworks, and evolving AML supervision can require pragmatic updates to a practice’s System of Quality Management (SQM) and AML procedures manuals. An outdated or uncustomised manual can create the impression that the practice has not translated its policies into its own operating reality.

System of Quality Management

Customised SQM Manual

EQC reviews, revises, or redrafts the SQM Manual around the practice’s own quality risks, governance, resources, client portfolio, acceptance procedures, monitoring arrangements, and remediation process. For SQM work, we use tracked changes to show clearly how and where the practice has modified the HKICPA templates. This creates a documented record of the practice’s customisations and supports the evidence expected by the AFRC.

Anti-Money Laundering / CTF

Customised AML / CTF Manual

The AML / CTF Manual is designed around the Hong Kong Guidelines on Anti-Money Laundering and Counter-Terrorist Financing for Professional Accountants and the practice’s actual client-acceptance, risk-assessment, escalation, screening, and record-keeping procedures. In addition to audit inspections, the AFRC has taken steps to perform AML compliance inspections (AMCI). Ongoing monitoring of accepted clients and their stakeholders should be supported by real-time searches at least monthly; this should be implemented promptly because searches cannot be backdated.

2027 Practising-Certificate Renewal Readiness

In July 2026, the AFRC advised CPA practices that it will follow up on SQM compliance, including external monitoring reviews, as part of the 2027 practising-certificate renewal process expected in November to December 2026. Practices should therefore review whether their SQM documentation, implementation evidence, monitoring reviews, and remediation records are current and available for regulatory follow-up.

Why EQC’s Documentation Approach Is Different

Practice-Specific, Not Generic

Policies and procedures are aligned to the way the practice actually operates, making them more practical to follow and easier to evidence during an inspection or monitoring review.

Inspection-Informed

Documentation is developed with a practical understanding of AFRC inspection expectations, including the importance of demonstrating implementation rather than merely retaining a manual.

Built for Ongoing Use

EQC focuses on frameworks that support recurring client acceptance, monitoring, training, escalation, and remediation work—not documents that are prepared once and then left unchanged.

A Practical Route to Documented Readiness

1Understand the Practice

Review operational structure, client base, service lines, quality risks, and current documentation.

2Identify Gaps

Assess the current SQM and AML / CTF framework against relevant requirements and current regulatory expectations.

3Draft and Customise

Prepare tailored revisions with clear tracked changes and practical procedures for the practice to implement.

4Support Implementation

Help management understand implementation priorities, evidence needs, monitoring arrangements, and follow-through actions.

Strengthen Your SQM and AML / CTF Framework

Speak with EQC about customised manuals, tracked-change documentation, external monitoring readiness, AML screening processes, and inspection-focused implementation support.

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