Anti-Money Laundering Manual And Procedures Template
(updated for MLR 2017 & 4MLD)
Attn: UK Financial Services…
“Finally! Your Own Editable Accurate and Up-to-date Anti-Money Laundering Policy & Manual”
(So you DON’T have to Trawl through all the FCA handbooks and 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!
UK AML Policy Template
From: Lee Werrell, Chartered FCSI, Master ISM
RE: Anti-Money Laundering Policy Document & Manual
Dear Financial Services Professional,
If you want your firm to conduct your accurate due diligence and be accurate and compliant with the latest (MLR 2017) rules, incorporating the 4th Money Laundering Directive (4MLD), 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 fast moving regulatory world where more responsibility is leveled at individual approved persons, this may just save your hide and keep you from receiving regulatory scrutiny or worse, censure!!
The Money Laundering Regulations 2007 were upgraded and revised by new legislation from the EU. The Fourth Money Laundering Directive (4MLD) was transposed into UK legislation in June 2017. It 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.
In a Hurry?
Top of Form
Bottom of Form
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?
“Financial firms must remain vigilant and continue to report any suspicions that they are in possession of the proceeds of crime to the Serious Organised Crime Agency, as well as informing the Treasury’s Asset Freezing Unit if they hold funds for a person or organisation on the government’s list.” Tracey McDermott, Director of Enforcement & Financial Crime, the FCA [Note: SOCA is now the NCA]
Here’s how and why we can make you this promise…
My Name is Lee Werrell, Owner of Compliance Consultant
I am an internationally published author of the “Compliance Manager’s Guidebook and Reference” as well as Risk Management and other books. 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. Whether you think you understood the MLR 2007 regulations or not, the Customer Due Diligence, Simplified Due Diligence and, most of all, the Enhanced Due Diligence rules have changed.
With Fines For Individual Directors and Compliance Officers/MLROs of over £270,000 (7) in 2016 and £225,000 (4) in 2017 – Things Are Getting Serious For Senior Managers.
In the FCAs Business Plan and Sector View for 2017/18 – a major risk is the “Insufficient spending on existing technology and oversight” including AML systems and due diligence methodologies that are not fit for purpose. Without the policy behind any system, the effectiveness is reduced considerably!
Tackling financial crime is a key part of the FCA’s remit. Financial crime informs all aspects of their work, from our 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 “… the measures firms take to detect and prevent fraud, money laundering, bribery, breaches of asset freezes. Our supervisors are supported by dedicated expert teams looking at these issues, and exploring practices in pockets of the industry seen as being potentially vulnerable.” Tracey McDermott, Director of Enforcement & Financial Crime, The FCA
The European Commission has published a new anti-money laundering Directive. The Fourth Money Laundering Directive (4MLD) effective from 26th June 2017 (known as the Money Laundering Regulations 2017) provides a common European basis for implementing the revised Financial Action Task Force (FATF) Recommendations. It also strengthens the risk-based approach to anti-money laundering and countering the finance of terrorism (AML/CTF) and aims to ensure the consistent application of rules across Member States.
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’)
Definition of 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 2017
Money Laundering Reporting Officer
Non Face To Face Clients
Non-Cooperative Countries and Territories
Proceeds of Crime Act 2002
Sanctions and Penalties
Screening of relevant employees
Simplified Due Diligence(‘SDD’)
Standard of Verification Evidence
ST/ARs – Suspicious Transactions/Activity Reports
Terrorism Act 2000 & the Anti-terrorism, Crime and Security Act 2001
The Risk Based Approach
Training and Awareness
Training Records applicable to Compliance and Fee Earners
Trusts, Foundations and Similar Entities
US Legal Obligations
Version control and management
Your Firm’s Policy Statement
Plus Panama Papers links so you can check your clients!
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 2017.
- AML due diligence has changed – make sure you are up to speed.
- Getting things right now is so much easier while you have breathing space before you get a visit notification.
- This manual 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 & Procedures
it provides you with all the answers and the must’s as well as the must nots. You get it as a fully editable document with instructions on changing the key areas to personalise it to your firm.
You get all of this for just £310 – £140 less than retail price! But hurry, this offer will close soon!
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
If “The Anti-Money Laundering & Counter-Terrorist Financing Policy” doesn’t show me exactly how to Be accurate and compliant with the latest (2017) rules… if it doesn’t take me by the hand, step-by-step Take comfort that this has been written for professionals by professionals and not some academic… or if it fails to help me Clearly articulate to all staff what is required as a firm’s policy and provide them with appropriate training and education, then I understand that I will receive a full refund, No Questions Asked!!
As you can see all the risk is squarely on my shoulders, so….
Here’s How To Order Right Now
So go ahead and click the order link now and you’ll be on your way to enjoying all the benefits we’ve talked about here and more! Let’s get started right now!
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Wishing you the very best, professionally and personally
Lee Werrell, Chartered FCSI Master ISMM