Anti Money Laundering

THERE ARE SIGNIFICANT CHANGES THAT REQUIRE YOU TO TAKE APPROPRIATE ACTION TO COMPLY WITH THE AML REGULATIONS 2017

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.