On Thursday 22 October, the SRA released their findings from their most recent thematic review in a piece of guidance on anti-money laundering policies, controls and procedures. AML policies, controls and procedure are one of our key controls helping us protect our firms against money laundering. Under Regulation 19 of the money laundering regulations, firms must establish, maintain, document and regularly review their AML policies, controls and procedures. The regulations have been with us over nine years, so why are we still not getting it right?

This session will look at the guidance in more detail including:

• Introduction – what are policies, controls and procedures
• The legal requirements from the MLR2017
• What the SRA did in their thematic review including:
  • Facts and figures – how many PCP’s reviewed are compliant
  • The most common mandatory areas missing from AML policies
  • Good practice and poor practice seen with regards to PCP’s
  • Monitoring compliance with AML policies, controls and procedures including:
    • File reviews
    • Checklists
    • Case management systems
    • Onboarding controls
    • Tailoring
  • Using a two-tiered approach
• Examples of tailored PCP’s
• Regulation 21 independent audits
• Summary

To attend, please email Alice.wylie@sussex-law.co.uk