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Anti-Money Laundering & Counter Terrorist Financing Policy Template UK
What is a firm doing to make sure it does not do business with people and organisations subject to asset freezes?
“Financial firms must remain vigilant and continue to report any suspicions that they are in possession of the proceeds of crime to the Serious Organised Crime Agency, as well as informing the Treasury’s Asset Freezing Unit if they hold funds for a person or organisation on the government’s list.” Tracey McDermott, Director of Enforcement & Financial Crime, the FCA [Note: SOCA is now the NCA]
Attn: UK Financial Services…
“Finally! How To Create an Accurate and Up-to-date Anti-Money Laundering Policy”
(So you DON’T have to Trawl through all the FCA handbooks and legislation)
A professional and practical policy that can be used in any firm
Show the regulator that you are on top of your responsibilities
Be clear about how you deal with the required due diligence, CDD, SDD and EDD!
From: Lee Werrell, Chartered FCSI FISMM
RE: Anti-Money Laundering Policy Document
Dear Financial Services Professional,
If you want Be accurate and compliant with the latest (2016) rules, Take comfort that this has been written for professionals by professionals and not some academic, or even if you just want to clearly articulate to all staff what is required as a firm’s policy and provide them with appropriate training and education, then this is the most important letter you’ll read all year!
In today’s fast moving regulatory world where more responsibility is levelled at individual approved persons, this may just save your hide and keep you from receiving regulatory scrutiny or worse, censure!!
Financial Crime is more active today and so it is no surprise that the establishment of The Office of Financial Sanctions Implementation (OFSI), a new enforcement body within HM Treasury (HMT), began operating at the end of March 2016. On 31 March 2016, HMT announced that OFSI has now been officially established to provide a “high-quality service to the private sector, working closely with law enforcement to help ensure that financial sanctions are properly understood, implemented and enforced”.
Tackling financial crime is a key part of the FCA’s remit. Financial crime informs all aspects of their work, from their scrutiny of new authorisation applications to day-to-day supervision of financial firms. They look at risks ranging from fraud and money laundering to data security breaches and violations of asset freezes.
On supervising firms; “We also perform a programme of rolling in-depth reviews of the anti-money laundering controls of the biggest institutions – the “Systematic AML Programme” as we call it.”
“In looking at the effectiveness of a country’s anti-money laundering defences, the IMF and FATF assessments put a lot of weight on clear evidence of action, such as prosecutions and enforcement. It is a yardstick by which many judge a regulator. But I want to assure you that no firm is referred to enforcement lightly. A lot of consideration is given to these decisions. Our Enforcement proceedings on financial crime issues are – and always will be – based on material failings in high risk areas. I have no interest in initiating enforcement action against firms for quibbling technical transgressions. An enforcement referral is in many ways a sad and bad outcome, not a signal of regulatory virility; it arguably shows failure by the regulator as well as failure by the firm.”
Speech by Rob Gruppetta, Head of the Financial Crime Department, FCA, delivered at the Accuity AML Risk Reduction and Compliance Europe Conference on 8 December 2015.
In Fact, Here’s Just The Tip of The Iceberg of What You Get alphabetically…
Account Opening Process
Capacity of the Client
Certification of Documents
Client Risk Assessment
Clients entitled to Simplified Due Diligence (SDD)
Clients Subject to Full Identification Requirements
Contact with Third Parties
Customer Due Diligence (‘CDD’)
Data Protection – Subject Assess Requests (SARS)
Dealing With Politically Exposed Persons (‘PEPS’)
Documentary and Electronic Evidence
Documents in a Foreign Language
Enhanced Due Diligence (‘EDD’)
Financial Action Task Force’
Financial Crime Risk
Higher Risk Clients
Introductions of Business by Intermediaries
Joint Money Laundering Steering Group
Law, Regulation and Industry Practice
MLRO’s On-going Risk Assessment
Money Laundering Regulations 2007
Money Laundering Reporting Officer
Non Face To Face Clients
Non-Cooperative Countries and Territories
Proceeds of Crime Act 2002
Sanctions and Penalties
Simplified Due Diligence(‘SDD’)
Standard of Verification Evidence
STRs – Internal and External
Terrorism Act 2000 & the Anti-terrorism, Crime and Security Act 2001
The Risk Based Approach
Training and Awareness
Trusts, Foundations and Similar Entities
US Legal Obligations
Your Firm’s Policy Statement
Plus Other Benefits;
Get Your Policy Updated Now!