Tag: risk based approach

  • 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.

  • financial criminals and disqualified directors in UK Companies House Register

    World-Check exposes terrorists, financial criminals and disqualified directors in UK Companies House Register  

    World-Check, in partnership with data quality specialist Datanomic, recently embarked on a project to screen the UK’s Companies House register of companies, company directors and secretaries against World-Check’s global database of high risk individuals and organisations.

    The underlying aim of the project was to identify the growing number of high risk individuals registering and operating businesses in the UK. Two articles appeared in The Times newspaper you can read them directly from the newspaper.

    The first article entitled ‘4000 company directors listed as global terror suspects and fraudsters’ and the second one ‘Buckinghamshire firm run by Croation war crimes suspect Ivan Cermak’.

  • Financial Action Task Force (FATF) statement

    Financial Action Task Force (FATF) statement

    Financial institutions in the UK should give special attention to business relations and transactions with persons, including companies and financial institutions, from jurisdictions that do not adequately apply the FATF Recommendations.

    The FATF is an inter-governmental body that develops national and international policies to combat anti money laundering (AML) and the financing of terrorism (CFT). It has released a public statement on several countries highlighting their concerns over deficiencies in their AML/CFT legislation.

    The countries are Iran, Pakistan, Uzbekistan, Turkmenistan, Sao Tome and Principe, and the northern part of Cyprus.

    More information on FATF can be viewed on their website.

    If you deal with any of the countries listed you should take account of these concerns in your AML Risk Assessment