Category Archives: AML and CTF

Getting Ready For The 6AMLD

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aml specialist consultants londonThe sixth anti-money laundering directive (6AMLD) is almost here. It has been n effect in EU member states since December 3, 2020, all financial institutions must implement the directive by June 3, 2021.

While there are fewer big changes than previous directives, 6AMLD brings clarity to specific regulatory details to close loopholes, toughen penalties, and encourage greater cooperation. Its goal is to empower financial institutions and states to do more in the fight against money laundering and the financing of terrorism.

UK financial services businesses

The UK has chosen to opt-out of abiding by further AML policy as the Government believes that domestic legislation is already mostly compliant with the Directive’s steps and, in most cases, goes even more than what 6AMLD proposes. For example, in the UK, the maximum penalty for money laundering is fourteen years, going beyond the new four-year minimum needed by 6AMLD; and aiding and abetting offenses of helping, motivating, and trying to launder money is currently a criminal matter.

However, it is essential to keep in mind that UK-based businesses in the monetary sector that operate within the EU jurisdiction will require to comply with the modifications set out in 6AMLD.

Access to clean and available international customer data for effective AML/ KYC screening

To be ready for 6AMLD, those in financial services require to know their clients, whoever they are. The key is to have access to billions of consumer records worldwide from trusted data streams; these consist of federal government firms, credit firms, and energy records for cross-check and verification purposes. It is particularly essential to obtain confirmation of important proof of address. Having access to up-to-date watch lists, such as politically exposed Persons (PEPs) information as part of this dataset is likewise essential.

From a customer experience perspective, the checks leveraging this data should take place in real time to prevent slowing the consumer onboarding procedure. This data should also originate from a single source to avoid the requirement for many expensive providers in various markets. This issue frequently results in irregular ID data and supply chain management issues.

Regtech: MRZ and ORC ID document scanning and biometrics to support 6AMLD compliance

When it pertains to remote onboarding, banks need to use machine legible zone (MRZ) and optical character recognition (OCR) innovations to gather customer ID and extract important details. This ensures the ID is real and validated in real time. The image ID embedded in these scanned documents supports biometric ID confirmation, such as facial acknowledgment, which can likewise help securely speed up consumer engagements.

Nevertheless, the biometric innovation must provide liveness checks, such as eye motion, for proof of life confirmation. This is vital with scammers significantly utilizing creative approaches like 2D images and video playback to try to trick facial recognition technology and ‘prove’ they are the person they are impersonating. In fact, this process can result in money services (MSPs) and Payment Service Providers (PSP) organisations getting a due diligence report related to AML and KYC that can be used to show their compliance when it comes to regulatory checks.

To prevent money being laundered and prevent extreme sanctions, financial services companies operating within the EU needs to comprehend and be ready for 6AMLD by the June due date. Ideally, this must involve having access to billions of consumer records worldwide for cross-check and ID confirmation functions, helping recognize individuals throughout borders. They must also undertake document scanning with MRZ and ORC innovation, which will also allow delivery of biometrics that help to safely speed up engagement with customers. Embracing these procedures will decrease the concern of compliance and equip financial institutions for more stringent global policies in the future.

 

If you have any questions or want further assistance, please contact us by email – info@complianceconsultant.org or call +44 (0) 207 097 1434

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The Importance and Value Of The MLRO’s Report

MLRO ANNUAL REPORT COMPLETION

importance-of-MLRO-Annual-Reports

The Financial Conduct Authority (FCA) have specific regulatory rules and requirements set out in the ‘Senior Management Arrangements, Systems and Controls (SYSC)’ section of their handbook, which relate to financial crime and specifically anti-money laundering officer, controls, measures and audits. SYSC 6.3.7 also specifies that the appointed Money Laundering Reporting Officer (MLRO) is to ensure the appropriate provision of information to its governing body and senior management, including a report, at least annually, on the operation and effectiveness of the systems and controls put into place to enable it to identify, assess, monitor and manage money laundering risk.

The MLRO has to produce an annual MLRO Report which is provided to Senior Management and made available to any regulating or governing body where applicable and/or requested. The report seeks to ensure the efficiency, effectiveness and adequacy of the AML/CFT measures, controls and systems in place and details any breaches, SAR’s, improvements and actions within the reporting period. 

MONEY LAUNDERING REPORTING OFFICER (MLRO) ANNUAL REPORT 
NOTE: We have compiled a list of the sections and just a few of the questions that we feel should be included on this annual MLRO Report – however it is essential that you add to and/or amend/expand the sections to ensure that they take into account the size, scope and scale of your business. Some areas have been removed for the sake of brevity. If you want assistance in designing your reports more effectively and comprehensively, lease contact us.
1. Company Details
MLRO Name:
Date Report Compiled:
2. Systems & Controls
a. Are the AML/CFT policy and procedure documents up-to-date? YES/NO 
b. Are they adequate to meet the firm’s needs & mitigate financial crime risks? YES/NO
c. Are they effective in meeting the regulatory & legal rules & requirements? YES/NO
d. Detail any areas where the firm’s AML policies, procedures, systems and/or controls should be improved, and proposals for making appropriate improvements?
e. Do the existing controls and measures ensure that your firm can identify, assess, monitor and manage money laundering risk? YES/NO 
f. Are client identification procedures effective and adequate? YES/NO
g. Have due diligence checks been completed & retained for all new clients? YES/NO
h. Are your Risk Management policies and procedures up-to-date? YES/NO 
i. Are they adequate to meet the firm’s needs & mitigate financial crime risks? YES/NO
j. Are they effective in meeting the regulatory & legal rules & requirements? YES/NO
3. Breaches & Reports
a. How Many Internal Suspicious Activity Reports (SAR’s) Were Completed?
b. Number of SAR’s Passed to the FCA/NCA?
c. Number of SAR’s NOT Passed to the FCA/NCA?
d. Were there any breaches of internal AML/CFT policies and/or procedures? YES/NO
e. Were there any breaches of FCA regulations with regards to AML/CFT? YES/NO
f. Were there any breaches of regulations/laws regarding AML/CFT YES/NO
4. Training & Assessments
a. Has appropriate and effective Financial Crime and AML training been provided to all employees and associated personnel? YES/NO
b. Have all training materials been reviewed for compliance with current laws, regulations and legislation? YES/NO
c. Are employees asked for feedback on the training content and delivery? YES/NO
d. Are assessment test papers used to test AML knowledge and understanding? YES/NO
e. What was the date of the last content update/review for training materials?
f. Have all staff received the training within the past 6 months? YES/NO
5. Due Diligence & High-Risk Clients
a. Is a due diligence checklist and questionnaire used for all new customers? YES/NO
b. Are adequate/effective background checks performed on all new customers? YES/NO
c. Are adequate/effective background checks performed for all new employees?    YES/NO
d. How many customers does the firms have that it categorises as ‘high-risk’? 
6. Due Diligence & High-Risk Clients
a. Are adequate/effective monitoring and audit procedures and controls in place? YES/NO
b. Based on the audit and monitoring outcomes, are the AML/CFT controls and measures deemed to be comprehensive and proportionate?    YES/NO
c. Are transaction monitoring processes adequate and effective? YES/NO
d. Were ‘Source of Funds’ checks carried out on all transactions over £10,000?YES/NO
7. Summary
Do they summarise any regulatory/legislative changes during the reporting period and their impact on the firm’s systems, controls and measures?
Do they summarise any impending and/or future regulatory/legislative changes that could impact the firm’s systems, controls and measures and suggestions for actions and/or mitigations?
Do they indicate changes in activity and elements of the business that have had implications for money laundering controls?

If you need to create, review or execute your Governance, Risk or Compliance strategy, call us today on

0207 097 1434 or email info@complianceconsultant.org.

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This guide is only an aide memoire and intended for information only for anyone appraising the documentation needed in an audit/compliance check. It is not to be considered as direct advice or intended to replace specific 1 to 1 engagement with your compliance and risk professional.

FCA Application Rejected or Declined?

The FCA often seem like faceless people making decisions on your future livelihood.

Sometimes their lack of, or even deluge of detail regarding their decision can make you frustrated or angry. This can cause upset and friction within the new business, either start-up or diversification. Business partners fly off the handle at the drop of hat.

Guidance and direction is freely available from the FCA but sometimes it seems they are talking a different language.

We can help you rectify the issues.

Often your application may lack the depth of content or description that the regulator looks for. They have a difficult job insomuch as they are there to protect the public from scams, charlatans, badly run businesses and any criminal activity that is inherent or who could take over your firm’s operations.

That’s where we can help. We have over 20 years regulatory experience and all of our consultants are qualified and experienced in their field. We don’t talk around the houses, we tell it to you straight. We will tell you what needs to be done, then help you do it, in partnership with us. 

But don’t take our word for it – See for yourself. Our reviews speak for themselves. Our Google Reviews are public knowledge , and rather than give you a link – please simply Google “Compliance Consultants London” and ‘Compliance Consultant‘ is usually top the leader board with the map – click on our Google Website Page, scroll down under the pictures and see the reviews. Alternatively, click HERE.

Whether your application is for AML Registration (Crypto etc) or an application to get authorised under any of the other financial services legislation (FSMA Part IV, PSD2 etc), we have the experience, the knowledge, the qualifications, and WE CARE!

 

Complete the form below – Call us on +44 (0) 207 907 1434

or Email info@complianceconsultant.org.

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FCA Decline/Reject CryptoAsset Firms

The FCA, under the 5th Anti-Money Laundering Directive have required firms to register with them for Anti-Money Laundering.

Many cryptoasset firms have had their applications rejected or recommended to withdraw due to a poor standard of completion. FCA Cryptoasset firm AML registration has been extended for existing applicants.

FCA cryptocurrency registration is akin to an authorisation and requires a lot of information, packaged in the right way. Additional forms need completing to accompany your application. If you use the wrong words, the FCA can see red flags and this will go against you.

We can help you, like all the other firms we help, to get your business on the right track and as long as your business model is sound – we can provide the right package for your next submission.

If you want to reapply with a greater potential of success, working with specialists who will work with you throughout the process, help answer any questions and advise you on the correct responses,  call the specialists in this area – Compliance Consultant, based in London and operates globally in regulatory matters including compliance and risk.

Call us on +44 (0) 207 907 1434 or email info@complianceconsultant.org

Contact Us Now!

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Crypto registration and FCA Guidance on applying

FCA Cryptocurrency Firm AML Registration

The FCA, under the 5th Anti-Money Laundering Directive have required firms to register with them for Anti-Money Laundering. Many firms have had their applications rejected or recommended to withdraw due to a poor standard of completion. We can help you, like all the other firms we help, to get your business on the right track and as long as your business model is sound – we can provide the right package for your next submission.

Call us on +44 (0) 207 907 1434 or email info@complianceconsultant.org

Get Our Free FCA CryptoAsset Registration Brochure

Cryptoasset registration brochure

CryptoAssets Brochure for firms requiring registration with the FCA for Anti-Money Laundering & Counter Terrorism Financing

 

No mess, No Fuss, No Emails required (unless you want to contact us) in which case; please complete the form below.

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To Download the Brochure Only; Just Right Click to download HERE

Compliance Support Services Explained

Once your organisation has accomplished authorisation, you’re dedicated to satisfy a variety of on-going FCA compliance responsibilities. Companies either pick our consultancy services to help resolve specific issues or to handle the effect and impact of new policy or we tailor a retainer agreement to satisfy their particular continuous requirements.

Retainer agreement
Our extremely skilled group of compliance specialists have market and regulatory backgrounds supplying an unique mix of skillsets and giving you the confidence that your continuous regulatory responsibilities will be satisfied to a high expert requirement.

With retainer service contracts separately tailored to your organisation we provide an agreed service delivery and schedule. Having operated in your sector, our professionals understand your compliance obstacles and opportunities. They share their backgrounds and understanding to solve issues; so you reap the benefits of a unique sum total of competence.
Supplying you with budget certainty and on-demand access to an extremely trustworthy compliance partner and a topic expert panel, usually, our retainer contracts include:
  • Compliance management; setting up and your Compliance Monitoring Programme, including automating it if required.
  • Compliance audits; independent bench-mark reviews and health-checks to make certain your systems, controls, policies and regulatory procedures are kept up to date
  • Documents/Governance; such as policies and written processes or procedures
  • Financial promotions including initial reviews and ongoing assessments or critiques, including video and social media marketing
  • Training; e.g., informing personnel on anti-money laundering or assisting senior management create a suitable governance framework
  • Regulatory reporting; consisting of GABRIEL returns and evaluation of prudential requirements
  • For Payment Services companies based on PSD2, we provide distinct service plans particularly created satisfy the increased regulatory needs and responsibilities.
  • And Capital Market companies gain from a specific methodology which permits us to craft a bespoke, flexible assistance package
  • Companies fall into the Asset Management, Broker Dealers & Traders, Corporate Finance, Crowdfunding, FinTech, Infrastructure, Investment Management, P2P Lending, Private Equity, Venture Capital and Wealth Management can all benefit from individual; and tailored packages.

Contact us today on 0207 097 1434 or email info@complianceconsultant.org

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    Fraud and Crypto – Human greed

    When it comes to AML and Fraud – this is a juicy case

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    UK Financial Services Compliance ‘Premium Access Retainer Service’

     

    We offer a Premium Access Retainer Service

    Providing Your Firm With Fast, Accurate, Experience Based Quality Answers So You Can Move Ahead With Your Business Efficiently and Profitably.

    We have a bespoke service starting from £600 pm.

    Our Full Services Obviously Has The Following 11 Benefits;

    1. You will get a response within 3 hours by phone or email/text.

    2. From PBR, S165 or S166 (we were appointed as skilled persons in 2012), we will advise and make recommendations regarding what is required.

    3. Your issues take priority over other work whilst we respond to your query; additional research or further work that may be required will be quoted on.

    4. Products like our best-selling Compliance Manual/AML Policy & Procedures are provided at a heavy discount typically around 40%.

    5. Any services we offer is again heavily discounted from 5  – 20%.

    6. Normal service is mainstream hours Monday to Friday but weekends and evenings are ad-hoc, although we often can be found working into the night or across the weekends at some point. Holidays excepted, but happy to take emergency calls.

    7. You will receive a monthly “Statement of account” before the next billing cycle or after a purchase.

    8. We work on a first come, first served basis, so anyone paying ‘Premium Retainer’ for the longer time, gets priority over the other Premium Retainer clients – if push comes to shove and we are snowed under.

    9. We occasionally have marketing promotions, and you get free gifts and/or free or heavily discounted event tickets for anything run by us.

    10. Also available for discussions on business strategy and marketing; areas we are also often asked about.

    11. 30 min telephone/video call per month to discuss your regulatory needs or issues.

    We only take on a maximum of 12 new clients per quarter. If you are too late for this quarter, we

     

    will add you to the list for the next quarter on a first-come-first-served basis.

    Monthly cost = £1,150 subject to firm size of less than 20 staff inc directors/partners.

      AML for UK Solicitors & Law Firms

      The SRA (Solicitors Regulation Authority) will be testing a sample of firms’ anti-money laundering policies every month as it increases efforts to combat misconduct in the profession.

      The solicitors regulator will also expand visits to every high-risk firm on a three-year rolling basis, along with visiting a sample of lower risk firms. The stepping-up of monitoring is revealed in a draft business plan for 2020/21, published this week.

      Findings from the reviews of firms’ procedures and controls will be published, with further reports to the Treasury and the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS). The SRA currently spends around 2.5% of its overall budget on AML activities, which is expected to rise in 2020/21 to 3% of the budget.
      The regulator has rightly identified money laundering as a priority risk amid concerns that solicitors, even oftentimes unknowingly, are supporting organised crime such as terrorism and drug trafficking. A previous review in 2019 found that over a third of firms had not made a full risk assessment, and half of the reports received by the SRA about money laundering involve not having carried out correct and proper due diligence on a client or their funds. To add to this, the Financial Action Task Force (FATF) has said in the past it was concerned about the relatively low number of suspicious activity reports filed by solicitors and other legal professionals in the UK.
      The SRA also plans to open a new office in Wales, as part of increased engagement with the profession in the country. This will mean it can work more closely with different groups, including the Cardiff office of the Law Society, on the key issues for Welsh consumers and the profession.

      Get your AML policy and procedures checked by qualified and experienced regulatory compliance professionals, just complete the form below and send it to us or call 0207 097 1434 to discuss your needs.

      See This Page Regarding The Governance Review & Recommendations Reports we provide, as well as re-write/create new policies HERE!
      DIY? See our AML Policy & Procedures Template On This Page
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