Category Archives: Financial Crime

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 – or call +44 (0) 207 097 1434

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The Importance and Value Of The MLRO’s Report



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. 

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

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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.

New Year – New Value

This post is to inform all new clients using Compliance Consultant, the FCA Authorisation  Specialists, that from 1st January 2021 our rates will be increasing by around 3% to combat cost rises and new expected efficiency tools supporting the remote working environment.

As FCA Authorisation Consultants, experienced and qualified, we will attempt to always add value to all of our services and include “extra” items where appropriate.


Merry Xmas 2020 and a Happy New Year 2021!



    FCA Authorisation Specialists, FCA Authorisation Consultants

    FCA Authorisation Specialists, FCA Authorisation Consultants

    Compliance Consultant, Compliance Regulations, Compliance Risk Assessment, Compliance Services, Compliance Solutions, Compliance Specialist

    Fraud and Crypto – Human greed

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

    Thanks to our Friend Samantha for spotting and sharing

    AML? 0207 097 1434 – We can review your processes compliantly!

    Money Laundering, Money Laundering Act 2017, Money Laundering Texas, Money Laundering With Bitcoin, Money Laundering With Cryptocurrency

    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.

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    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%.

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      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

      URGENT: Crypto – The FCA Deadlines for Anti-Money Laundering (AML) Registration


      URGENT: Crypto – The FCA Deadlines for Anti-Money Laundering (AML) Registration

      URGENT: Crypto – The FCA Deadlines for Anti-Money Laundering (AML) Registration

      There is Much Confusion Regarding The Need For AML Registration Among Firms In The UK.

      If you are conducting any exchange of cryptoasset for money or any other medium of exchange, as a business in the UK, then you need to be registered for AML with the FCA.

      What Do They Mean By Cryptoasset?

      “cryptoasset” means a cryptographically secured digital representation of value or contractual rights that uses a form of distributed ledger technology and can be transferred, stored or traded electronically;

      How Is Money Defined?

      “money” means—
      • money in sterling, or money in any other currency, or
      • money in any other medium of exchange, but does not include a cryptoasset; and
      • it can also mean that “cryptoasset” includes a right to, or interest in, the cryptoasset concerns

      So What Do I Have To Be Doing In My Business To Be Caught By The Regulations?

      There is a range of definitions in the legislation that confirms the regulated activity, but if you are a Cryptoasset exchange providers and custodian wallet providers the you are likely to be caught.
      In the Money Laundering Regulations, a cryptoasset exchange provider means a UK business that by way of business provides one or more of the following services, whether and including if they do so as creator or issuer of any of the cryptoassets involved, when providing such services.
      These services are
      (a) exchanging, or arranging or making arrangements with a view to the exchange of, cryptoassets for money or money for cryptoassets,
      (b) exchanging, or arranging or making arrangements with a view to the exchange of, one cryptoasset for another, or
      (c) operating a machine which utilises automated processes to exchange cryptoassets for money or money for cryptoassets.
      Again, in the Money Laundering Regulations a Custodian Wallet Provider means a UK business who by way of business provides services to safeguard, or to safeguard and administer cryptoassets on behalf of its customers, or private cryptographic keys on behalf of its customers in order to hold, store and transfer cryptoassets, when providing such services.
      So, if you have a UK registered office and carry on a day to day management of these activities, or operate an ATM facility in the UK (irrespectice of the geographic location of the cryptoasset activity is conducted) or have any UK presence that is engaged in or facilitates cryptoasset activity, you will likely need to be registered by the FCA to operate from 10th Jan 2021.
      However, the FCA have warned that to do this, you need to register before the 30th June 2020 for applications from existing businesses (operating before 10 January 2020) to be received for priority review to check that they are ready to be determined. For existing firms, if they do not submit a complete application by 30 June 2020, the registration may not be processed by 10 January 2021 and if they are not registered with the FCA, on 10 January 2021 they will have to cease trading.
      New businesses will need to be registered before 10th Jan 2021 or they will have to cease trading on that day until they are.

      We can help you and have facilities open over the next 10 days to assist your firms in their registration. There are several things you need to have in place and we will help you in this area. Call early to avoid disappointment as our pipelines are getting busy.

      Email or call 0207 097 1434 NOW!

      Claims Management Companies CMCs Compliance Procedures Manual and Financial Crime Policy

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      Having worked with a number of Claims Management Companies CMCs in recent days, we are happy to provide the following service to those who have not yet put their Compliance Procedures Manual (around 100 pages) and Financial Crime Policy in place.

      Contact us for details and timescales, but we will make them personalised to your firms.

      Cost £225

      Please complete your details below.

      [ninja_form id=1]


      Fraud including Credit Card Fraud and Suspicious Transactions Course

      Fraud including Credit Card Fraud and Suspicious Transactions Course

      credit card fraud core categories of a risk based approach

      Complete the form below to contact us!

      What Makes Compliance Consultant Courses Different
      • We have been delivering training for over 20 years and this is one of our core competencies. We believe we are experts on this topic and having delivered training to a wide range of firms and businesses, we are certain we know the topic as well as anyone in the market place
      • Your course director is a highly successful and experienced executive who will pass on past experiences and “war stories” generally to enhance the workshop and help bring it to life
      • We do not use academics. All our trainers are highly experienced professionals with relevant vocational experience in the real world
      • We have delivered many fraud and financial crime courses over the last few years and have a very clear understanding of what may be contributing to the fraud. In addition, participant feedback informs us in both a precise and timely manner what the changing regulatory imperatives are over time.
      • We have developed highly interactive and very enjoyable case studies to enhance the learning points. All delegates report that these are a high point
      • We are always judged by our results which speak for themselves and the feedback received from previous delegates has always been excellent
      Course Objectives
      • The aim of the Course is to provide fraud managers and others to obtain a wider understanding of risk management within the context of external fraud.
      • The delegates will have the ability to understand fraud risk in the wider context of enterprise risk management and business in general.
      • If you are responsible for drawing up financial policies as part of your job, this course will help you decide which checks/framework to put in place and how to enforce them
      • If you have been investigating or det4ecting fraud, this course may help you understand the perpetrator’s motives and the various factors that prompted their actions
      • This course will help you identify suspicious behaviour, which in turn will allow you to play your part in tackling this common crime.
      • This will include the ability to conduct a fraud risk assessment and manage the findings.
      Course Content
      Session 1
      • So You Have A Fraud Situation, Really?
      • What’s the difference between fraud and bribery/blackmail?
      • 11 Common Types of Credit Card fraud & crimes
      • 8 Types of identity theft and ways to spot them
      • Definitions, types of fraud, scale and typologies
      Session 2
      • AML MLR 2017 S33, 37 & 38 – What Makes A Suspicious Transaction?
      • Difference between Suspicious Activity & Suspicious Transactions.
      • 19 Red Flags for AML/CTF
      • Where are Suspicious Transactions identified?
      • CDD & EDD Monitoring
      • The legal requirement to monitor Suspicious Transactions.
      • Suspicious transactions, involving;
      • Investment Fraud
      • Loan/Credit card application fraud
      • Other miscellaneous fraud
      Session 3
      • The Modern Fraud Risk Management Framework
      • The drivers of financial crime, offending and the types of financial crime commonly encountered.
      • The international frameworks designed to help counter financial crime.
      • How will 2FA beat Card Fraud?
      Session 4
      • The Fraud Triangle
      • The people problem: motives and behavioural issues behind fraud – the Fraud Triangle, who commits fraud and why
      • Role of directors and Responsibilities of senior managers for fraud prevention and detection.
      • The role and responsibilities of auditors in fraud prevention and detection.
      Session 5
      • Workshop of scenarios (with PM break as appropriate)
      • 11 most common forms of credit card fraud.
      • Application Fraud
      • Electronic or Manual Credit Card Imprints
      • CNP (Card Not Present) Fraud
      • Counterfeit Card Fraud
      • Lost and Stolen Card Fraud
      • Card ID Theft
      • Mail Non-Receipt Card Fraud
      • Doctored Cards
      • Fake Cards
      • Account Takeover
      • Quiz: Are They A PEP or Not a PEP?
      Session 6
      • Assumed Identity involving some or all of the following 8 types of identity theft;
      • Financial Identity Theft
      • Driver’s License Identity Theft
      • Criminal Identity Theft
      • Social Security/Gravestone Identity Theft
      • Medical Identity Theft
      • Insurance Identity Theft
      • Child Identity Theft
      • Synthetic Identity Theft.
      Course Conclusion
      Your Course Facilitator/Director Backstory
      Your course director has spent over 30 years in the banking and financial sector, much of it in a Senior Managerial/Director role. A highly successful, long and varied “fast track” career in Banks led him to very senior management at an early age. Challenged by the industry reluctance to adopt regulated principles, he entered compliance 20 years ago and has run a successful consultancy ever since.

      The trainer has been a freelance training consultant since 2000 and is an expert on FCA and regulatory compliance generally. As a Chartered FCSI he has also created and delivered training to a vast range of clients from global giants to small partnerships. He is an accomplished global trainer and has delivered extensive programmes in the UK, Europe, Africa, and the Middle East.

      He is a highly adaptive, hands-on and highly sought-after facilitator who always receives excellent feedback from delegates. He is comfortable training at any level of seniority and experience from “black belts” to novices. His expertise includes but is not limited to Regulatory Compliance, Risk Management, Trade Finance, FCC & AML and all aspects of Corporate, Private & Retail Banking.

      Lee has written several books, available at Amazon including “The Compliance Managers Guide & Reference” and “Conduct Risk”.

      He is also a highly experienced soft skills trainer and has completed numerous “train the trainer” assignments.

      Online Courses you may be interested in

      SMCR For Limited & Core Firms – Click on this link =>

      Digital Onboarding for Fintech Firms – Click on this link =>

      Need a Compliance Manual? Our Top-selling Template is available HERE

      Need an AML & CTF Policy and procedures template? Our Top-selling Template is available HEREaml template fca mlr2017







      This Course Can Be Presented In The Following Formats:


      Public Course

      Future Dates Not Yet Available


      Face to Face In-House


      This course can be tailored and presented in-house at your location for 3 or more participants.


      From £850


      Live In-House Webinar


      This course can be tailored and presented exclusively via live webinar for your company for a group of participants. Participants are given a link and login and the trainer presents the course to a maximum of 20 participants.

      Participants can login from different offices.

      From £850


      Pre-Recorded In-House Webinar


      The trainer records the course exclusively for your company – in one session or in “bite-size” video files. We provide access to our Proprietary Online System, the whole course as a pdf and any supporting course materials for an agreed amount of time (6 or 12 months) for any number of participants up to 5,000.

      From £3,000

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