Q. What is my supervisor looking for me to do?

Q. What is my supervisor looking for me to do?

In simple terms there are four main things which all firms must do and be able to demonstrate compliance to a Supervisor, they are:-

  1. Your firm must adopt appropriate policies and procedures for compliance for which the MLRO must implement into the systems of the firm.
  2. Ensure that all staff have adequate training on understanding their roles and responsibilities under the UK’s AML regime, the offences for ML and procedures including client due diligence and reporting.
  3. Conduct client due diligence (CDD) procedures on all clients no matter how long they have been clients, including those pre 1 March 2004 clients at an appropriate time, including risk assessment, identity and verification and ongoing monitoring. 
  4. Implement a reporting regime for the reporting of Suspicious Activity Reports (SAR’s) to the Serious Organised Crime Agency (SOCA).  

You must ensure that all these policies & procedures, evidence of identity and account opening procedures, internal & external reports and any other AML procedural matters are documented correctly and records kept for a minimum of 5 years.

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