Anti Money Laundering

There are significant changes that require you to take appropriate action to comply with the AML Regulations 2017

Here is an overview of the changes & your obligations:

  • You must carry out an AML risk assessment for your firm and document it.

  • You must have written and up to date AML and data protection policies, controls and procedures including record keeping and evidence of auditing.

  • You must have a nominated Money Laundering Compliance Officer (as well as an MLRO) carrying out a proactive role to ensure compliance.

  • There are new obligations about screening employees to assess skills, knowledge and expertise.

  • There are more robust guidelines on when to carry out enhanced due diligence or when you can apply simplified due diligence.

  • The definition of a PEP now includes domestic UK based individuals.

  • Electronic Verification – your ability to rely on EV is now more possible on a risk-assessed basis.

  • Companies – there is more detail about what checks you must carry out when you are engaged by a company.

  • Trusts – a new definition of “beneficial owner” plus major new duties regarding trustees.

  • Demonstrate and record ongoing AML and data protection training within your firm.

If you require any assistance with the implementation of new policies and procedures to comply with the new AML Regulations 2017 please contact Brian Greevy for an initial discussion, or to arrange a no-obligation appointment at your office.

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