“Finally! How To Create an Accurate and Up-to-date Anti-Money Laundering Policy” – Now Updated for the MLR 2017!
(So You DON’T Have To Trawl Through All The FCA Handbooks and AML Legislation)
A professional and practical policy that can be used in any firm
Show the regulator that you are on top of your responsibilities
Be clear about how you deal with the required due diligence, CDD, SDD and EDD
Includes latest MAR Reporting Requirements (Sept 2016)
Also Includes New Account Opening Procedural Guide
From: Lee Werrell, Chartered FCSI FISMM
RE: Anti-Money Laundering Policy Document
Dear Financial Services Professional,
If you want your firm to be accurate and compliant with the latest (MLR 2017) rules, incorporating the 4th Money Laundering Directive (MLD4), take comfort that this has been written for professionals by professionals and not some academic, and if you just want to clearly articulate to all staff what is required as a firm’s policy and provide them with appropriate training and education, then this is the most important letter you’ll read all year!
In today’s ever fast moving regulatory world where more responsibility is levelled at Senior Management Functions,Certified Individuals and Individually Approved Persons, this may just save your hide and keep you from receiving regulatory scrutiny or worse, censure and/or fine.
The new MLD4 has introduced new elements into the exiting regulations that require your attention and action. A lot of the changes are subtle, but failure to comply, in today’s heightened awareness of terrorist activity is likely to be seen as reckless.
The Final Legislation that was submitted and approved by the House of Commons on 22nd June 2017 and included 4 amended or new points that were not in the final draft issued in April 2017!
These four points cover;
- Risk Assessment & Review
- Internal Controls
Your compliance service provider may well have told you about these, unless they relied on the final draft rules that were published in April. If you don’t include them (we tell you what they are in the manual) then you could fall foul of the rules and receive regulatory censure or worse.
What is a firm doing to make sure it does not do business with people and organisations subject to asset freezes?
Here’s how and why we can make you this promise…
My Name is Lee Werrell, Owner of Compliance Consultant and a Chartered Fellow of the Chartered Institute of Securities & Investment – CISI (pre-2010 known as the SII), and a Fellow of the Institute of Sales & Marketing Management.
I am an internationally published author of the “Compliance Manager’s Guidebook and Reference“, “Conduct Risk” as well as many other books (See My Amazon Page). I have built my business based on achieving the right outcomes and, to quote the Compliance Consultant tagline “Making Compliance Work“
Financial Crime and Anti-Money Laundering is increasingly being scrutinised by not only the FCA but PRA as well.
In the FCAs Business Plan and Sector View for 2017 – a major risk is the “Insufficient spending on existing technology and oversight” including AML systems that are not fit for purpose. Without the policy behind any system, the effectiveness could be reduced considerably!
Financial Crime is more active today and so it is no surprise that the establishment of The Office of Financial Sanctions Implementation (OFSI), a new enforcement body within HM Treasury (HMT), began operating at the end of March 2016. On 31 March 2016, HMT announced that OFSI has now been officially established to provide a “high-quality service to the private sector, working closely with law enforcement to help ensure that financial sanctions are properly understood, implemented and enforced”.
Tackling financial crime is a key part of the FCA’s remit. Financial crime informs all aspects of their work, from their scrutiny of new authorisation applications to day-to-day supervision of financial firms. They look at risks ranging from fraud and money laundering to data security breaches and violations of asset freezes.
On supervising firms; “We also perform a programme of rolling in-depth reviews of the anti-money laundering controls of the biggest institutions – the “Systematic AML Programme” as we call it.”
“In looking at the effectiveness of a country’s anti-money laundering defences, the IMF and FATF assessments put a lot of weight on clear evidence of action, such as prosecutions and enforcement. It is a yardstick by which many judge a regulator. But I want to assure you that no firm is referred to enforcement lightly. A lot of consideration is given to these decisions. Our Enforcement proceedings on financial crime issues are – and always will be – based on material failings in high risk areas. I have no interest in initiating enforcement action against firms for quibbling technical transgressions. An enforcement referral is in many ways a sad and bad outcome, not a signal of regulatory virility; it arguably shows failure by the regulator as well as failure by the firm.”
Speech by Rob Gruppetta, Head of the Financial Crime Department, FCA, delivered at the Accuity AML Risk Reduction and Compliance Europe Conference on 8 December 2015.
In Fact, Here’s Just The Tip of The Iceberg of What You Get alphabetically…
Account Opening Process
Capacity of the Client
Certification of Documents
Client Risk Assessment
Clients entitled to Simplified Due Diligence (SDD)
Clients Subject to Full Identification Requirements
Contact with Third Parties
Customer Due Diligence (‘CDD’)
Data Protection – Subject Assess Requests (SARS)
Dealing With Politically Exposed Persons (‘PEPS’)
Documentary and Electronic Evidence
Documents in a Foreign Language
Enhanced Due Diligence (‘EDD’)
Financial Action Task Force’
Financial Crime Risk
Higher Risk Clients
Introductions of Business by Intermediaries
Joint Money Laundering Steering Group
Law, Regulation and Industry Practice
MLRO’s On-going Risk Assessment
Money Laundering Regulations 2007
Money Laundering Reporting Officer
Non Face To Face Clients
Non-Cooperative Countries and Territories
Proceeds of Crime Act 2002
Sanctions and Penalties
Simplified Due Diligence(‘SDD’)
Standard of Verification Evidence
STRs – Internal and External
Suspicious Activity Report
Suspicious Transactions & Orders Reporting
Terrorism Act 2000 & the Anti-terrorism, Crime and Security Act 2001
The Risk Based Approach
Training and Awareness
Trusts, Foundations and Similar Entities
US Legal Obligations
Your Firm’s Policy Statement
Plus Other Benefits;
- Getting your AML & CTF as well as other financial crime policies and procedures right today will make the transition to the new rules that much easier, saving you hours or even thousands of pounds into the bargain!
- By reviewing and instigating a robust and accurate AML & CTF Policy today will save hours of trying to understand the new changes as well as trying to find specialists to explain to you what may have changed, and more importantly, what you need to do about it.
- This policy template has all the latest changes to date incorporated from the JMLSG changes 2013 to the transition to the National Crime Agency.
- Getting things right now is so much easier while you have breathing space before you get a visit notification.
- This policy is comprehensive and clear, with all the processes required, legislative references and penalties as well as ideas and workable processes for your firm to adopt, saving you frustration, heartache and a lot of pain into the bargain
So Here’s The Bottom Line With The Anti-Money Laundering & Counter-Terrorist Financing Policy
provides you with all the answers and the must’s as well as the must nots. You get it as a fully editiable document with instructions on changing the key areas to personalise it to your firm’s needs.
You get all of this for only £240
But Let Me Sweeten The Pot For You Even More With These Instant Bonuses For Acting Now…
Bonus #1: Compliance Manual Template Discounted Purchase Price (details HERE)
You will get details of a 25% discount on a template copy of our best-selling Compliance Manual in the email accompanying your purchase.
Real Value: £385 to Priceless
And you have nothing to lose because you can…
Take A Full We provide 60 Days No Quibble Money Back Guarantee To Put Us To The Test With Our Iron-Clad, Money-Back Guarantee
As you can see all the risk is squarely on my shoulders, so….
Wishing you the very best, professionally and personally
Lee Werrell, Chartered FCSI FISMM