Money Laundering Regulations 2017 Changes

Money Laundering Regulations 2017 Changes
As you know, the 26 June 2017 saw the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”) came into force, having been made, laid before Parliament and approved all on 22 June 2017.

Regulated businesses are now faced with the inestimable task of ensuring both their firm-wide and client-specific risk assessment processes and procedures are sufficiently robust to comply with MLR 2017 – after the commencement date.

If you use an external Compliance Service, they may well have provided you with an update on the legislation before it came into force, however, anyone who used the original draft in the belief that they would be the final rules will have failed to identify key points that are required by firms, that have been changed or were introduced in the final legislation.

Questions You Need To Ask

1. Have we reviewed the definitions and procedures in accordance with the MLD4?
2. Have we updated the CDD/EDD/SDD and Beneficial owner sections?
3. Have we trained our staff on the changes?
4. Is our policy up to date?
5. Is our policy approved by the board?
6. Would our AML/KYC/FC preparations or current arrangements stand up to independent external scrutiny?
7. Do you need to review the ‘state of play’ within your firm?

If the answer to ANY of these questions is “NO”You Need Our Help.

After a comparative analysis of the draft Regulations and the final MLR 2017 from the draft published by HM Treasury in April 2017 there are key differences which we have identified below.

Risk Assessment & Review
At your business level, two risk assessments are required. A business-wide risk assessment of money laundering and terrorist financing geographical features, transactions, products and delivery channels, as well as a specific risk inquiry prior to the commencement of each client relationship and, following a consideration of customer type, indeed, during the course of the relationship.

Governance Requirement
Regulation 19 of the Act shows a positive duty on regulated businesses to “regularly review and update” such policies and controls has been inserted in Regulation 19( 1)(b). Businesses will also be required to maintain a written record of all changes to AML policies, controls and procedures made because of a review plus all “steps taken to communicate” the changes to staff. This means that your version control is now of paramount importance. A similar requirement applies in Regulation 20 to parent companies in the UK, falling within the scope of a “relevant” (regulated) person.

Internal Controls
Alongside the requirement to implement and regularly review AML policies and procedures, is a requirement in Regulation 21 that regulated persons implement internal controls applicable to employees engaging with compliance matters. Previously, the draft Regulations required a firm to “carry out screening of relevant employees and agents” at regular intervals. “Screening” relates to assessing the skills, knowledge and expertise of a particular individual. The final version of the Regulations, however, has slightly lessened the compliance burden in one respect by dropping the reference to “agents” in Regulation 21.

Training records
A duty to maintain written records of training provided to relevant employees, which practically would include all fee earners and those in the Compliance function, also appears in Regulation 24. No such duty featured in this April’s draft Regulations.

Special Offers For Limited Number And/Or Date
If you want to get an up-to-date AML & CTF Manual, please click on this link (http://aml-compliance-manual-ofac-sanctions-ctf.co.uk) and use the code “CCMLD4” in the payment box.

Hurry because this only valid for the first 25!

If you want to take advantage of our policy checking offer, go to our special offer HERE but hurry, this is only on sale until the 31st August!

Money Laundering Regulations 2017 Changes

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How Can You Adapt To The Growing Rate Of Regulatory Change With Confidence?

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How Can You Adapt To The Growing Rate Of Regulatory Change With Confidence?

How Can You Adapt To The Growing Rate Of

Regulatory Change With Confidence?

Regulatory Change Management
For three years now we have provided a fundamental and key approach to the regulatory change management process, offering clients a clear and transparent understanding of their business lines, referenced against the regulators handbook and effectively mapping operations ensuring that clients can easily and simply identify areas impacted whenever their is a relevant regulatory development.

What We Cover Here

  1. Tracking & Monitoring Regulatory Events
  2. Mapping & Assigning Regulatory Developments
  3. Evaluate and Identify Impact
  4. Demonstrate Compliance

Track and monitor regulatory events
Compliance Consultant Regulatory and Risk Based Footprint Mapping, is a spreadsheet based solution that is created covering all of your operational areas to provide you with comprehensive coverage of legislative and regulatory content “at a glance”.

You can easily identify if changes occur in a specific handbook not only which areas are impacted (Level 0 – Regulation) but also on a level 1 basis for Business Conduct and Business Regulation, right to the chapter level. With handy hyperlinked text, you can go straight to the handbook section that applies to you.

Additionally, for 6 months you will be a member of our “Informer” regulatory awareness service, keeping you up to date with articles and posts by those who know what’s what in financial services.

You can also sign up for our free weekly “Regulatory Specialist” digest newsletter, delivered to your inbox http://paper.li/ComplianceConst/1411645553#/ or from our blog at http://www.complianceconsultant.org/blog/compliance-news/

Map and assign regulatory developments
Regulatory and Risk Based Footprint Mapping provides simplified mapping capabilities and complete taxonomy support, providing clean and effective line of sight for emerging regulatory issues. This ensures relevant information can be sent to the right stakeholders to manage and helps minimise compliance risk.

Through this connected approach, this helps your firm foster a deeper understanding of the regulatory developments affecting day-to-day business processes and reduce your total compliance effort.

With Compliance Consultant Regulatory and Risk Based Footprint Mapping you have the added assurance that your regulatory requirements are mapped across the entire enterprise. You can set up templated emails to automatically notify business owners each time a regulatory change occurs, and teams can easily assess who is in charge of particular developments, what level of risk is associated with that change, and any key information, without the need for expensive and often intrusive software.

Evaluate and identify impact
Once your organisation has established that the relevant regulatory developments are being tracked, Compliance Consultant Regulatory and Risk Based Footprint Mapping then assists your compliance teams perform impact assessments to determine which business units, controls, policies, and procedures were affected by any change.

Demonstrate Compliance
Added to this, you can also build in as a standalone declaration of all the impacted areas and provide evidence of compliance, suitable for audit or external inspection (such as risk rating agencies, stakeholders or committees by adding in the Compliance Charting Tool. By using this declaration of compliance as a central register and provider of comfort for senior management, you can easily update it as and when the regulations change.

By using version control, this full process ensures you have a complete audit trail to evidence to regulators what steps were taken to remain compliant.

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FCA Authorisation: What Does It Cost And Why Compliance Consultant Is Your Best Option

FCA Authorisation: What Does It Cost And Why Compliance Consultant Is Your Best Option

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We can tell you how long the application is likely to take and the best ways to “Package” your application to satisfy the case officer reviewing your application.

Our prices are fixed and typically a lot cheaper than most companies. Beware of the extras that others charge like providing required policies, help with completion of the documents etc.

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The Responsibility of Compliance Directors Is Growing And It Is Vital They Have Their Finger On The Pulse.

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Instruction book on how to perform a role under UK regulatory requirements for a firm to meet compliance.

As a UK Financial Services Regulatory Compliance Executive who desires to be sure they have all bases covered before any regulatory visit; or maybe wish to know the secret tips of compliance risk assessments and business or operational risks; or perhaps are new in the job and want insights into hot-topics, enforcement and regulatory methodologies and best practice. If so then the “Compliance Manager Guidebook & Reference” is written for you.

Regulatory Compliance is constantly changing and many people need to know; What do the most recent changes mean? What changes have happened to the regulatory Handbooks? What effect does this have on the sales process? Does the documentation have to be adjusted? Does the sales process have to be amended? Whenever these questions are asked, everyone turns toward “compliance” to find out. If you are new or an old-timer, you have to know what the latest changes are and the best ways to apply the requirements to your firm. If you need any of this and may want to develop the role of the compliance officer within the compliance function or the entire firm then help is at hand.

If you are hoping to discover the affect on compliance and identify areas that cause concern to most compliance professionals, then you’re about to discover how to start improving, today! In fact, we will deal with a number of aspects of the role of the Compliance Manager concerning the regulators and the regulators current perspective and hotspots, by having this Ebook “Compliance Manager Guidebook & Reference”, the most suitable selling Ebook of it’s type, gives you the answers to 17 important questions and challenges every Compliance Manager faces, including: The regulatory terrain; how did this evolve to today’s landscape? How do you map your firm’s actions to the compliance universe? Good and bad compliance and forming a compliance charter. What do you have to perform a Compliance Risk assessment? How do you involve senior management and other departments in their compliance responsibilities? … and more!

Whilst this guide is designed to provide a medium level of information, it is not a Janet and John Guide. We have not, as an example entered into the basics of financial promotions or suitability, completing fact finds or writing suitability reports as there is already help and guidance available at that level. We do not describe how to complete a regulatory online return as it is assumed that you are already an established financial services professional and have been involved in compliance for at the very least two years. So, if you’re serious about improving your role as the compliance officer and identifying good and bad practice and the affect on compliance within your firm then you need to grab a copy of “Compliance Manager Guidebook & Reference” now, because the leading compliance and business risks consultant, Lee Werrell of Compliance Consultant (http://www.complianceconsultant.org), who has over 25 years experience in financial services and compliance (and is a Chartered Fellow of the CISI – FCSI) will reveal to you how every a Compliance Manager can succeed in establishing themselves, and; Provide meaningful data, Deal with inquiries in a professional manner whilst remaining consistent in the answers, Maintain adequate governance throughout the firm, Create a single contact point for the regulators, Know the Approved Persons regulations, Know where to search for the relevant rules or guidance, Plan for regulatory visits and communicate effectively with the regulator and ensure your firm remains compliant in every aspect.

Any purchasers of this book will be entitled to a FREE copy of the revised edition due in early 2018. Simply send proof of purchase to info@complianceconsultant.org.

August 2017 Offer

August 2017 Offer

We all know that the summer months can be quiet for IFAs and what better time to get those awkward jobs dealt with?

At Compliance Consultant we also know that whether you are independent or restricted, there are a number of issues that might need addressing.

The “umbrella” compliance support companies provide a great service, but the FCA doesn’t approve of  downloadable templated “Disclosure Documents” or “Suitability Reports” where they are not personalised sufficiently and contain TOO MANY IRRELEVANT FACTS!

“We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure …….. further work is required by the sector”

The FCA stated in their report on “Suitability” in May  that “We are disappointed with the disclosure results with only 52.9% of sampled cases providing acceptable disclosure and further work is required by the sector to improve the initial disclosure (includes firm’s costs and services).”

Having met with the FCA Supervision Team (authors of the report) recently we have a good handle on what they mean and what they hoped to see already in place. Additionally there was also a great deal of discussion around the suitability letter construction and what content should be included.

Regarding the Senior Managers & Certification Regime, (https://www.fca.org.uk/firms/senior-managers-certification-regime/solo-regulated-firms) we have already worked on this for banking groups and know what is involved, the final tweaks are awaited but

In the details released on 26th July 2017, the FCA said the requirements will include “responsibilities maps, handover procedures, and will need to make sure that there is a senior manager responsible for every area of their firm”.

This means that your procedures need to be identified, mapped and recorded with owners and relevant controls.

What We Are Offering

To Help You Ensure You Are Comfortable With Your Compliance Affairs, We Have Two Offers;

5 Days Work for the price of 4

If you have a piece of work that needs doing, we will arrange to provide 5 days service either at your work site or from a distance (typically report writing etc) at a 20% Discount if at least 5 days work is booked.

What Does This Mean?

This means simply whereby we might normally charge in the range of £500 to £1,200 for a days’ consultancy work of one or more consultants, over a week that would be £2,500 to £6,000

with our offer that is reduced to £2,000 to £4,800 and no VAT!

As An Extra

We Operate A “Benchmarking Audit” and that is on special offer until 4th August from £2,600 discounted to £2,080 with no VAT!

We can offer these discount ONLY FOR WORK BOOKED IN BY

5.00pm 4th AUGUST 2017

CLICK HERE to register your interest and get a copy of our

“Suitability Guide” absolutely Free!

Don’t want the guide? Need to talk to us straight away? Call 0203 815 7939 now!

Why Not Join Our Free IFA Compliance Advice Facebook Page https://www.facebook.com/groups/IFAComplianceUK/