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Money laundering

For senior management in firms regulated by the Financial Services Authority ('FSA'), HM Revenue & Customs, the Office of Fair Trading, or other UK supervisory body, key risks to manage, include:
  • Targeting AML systems and control to address risks relevant to the business.
  • Maintaining appropriate client acceptance procedures, to mitigate money laundering risk (including due diligence for standard and higher risk customers/counterparties).
  • Providing an internal reporting process to capture money laundering suspicions.
  • Appointing a Nominated Officer and/or Money Laundering Reporting Officer ('MLRO').
  • AML training for relevant employees who deliver (or supervise) regulated business.
  • Complying with systems and control requirements of the Money Laundering Regulations.
  • Oversight of regulated activity outsourced to third party service providers.
  • Validating application of AML systems and control in practice.
  • Complying with regulatory requirements (e.g. the FSA Handbook).
  • Ensuring that internal AML arrangements reflect good practice (e.g. as set out in Joint Money Laundering Steering Group ('JMLSG') Guidance).

FCRM provides anti money-laundering ("AML") services to clients, assisting them to manage and respond to requirements of the UK's AML and Financial Sanctions regime.

R
Launder

"To move money obtained illegally through banks and other businesses, to make it appear to have been obtained legally."

UK financial services firms regulated by the FSA are required to maintain effective systems and controls to mitigate money laundering risk; and they must also comply with the requirements of:

  • SYSC 3.2.6R - Systems and controls in relation to compliance, financial crime and money laundering.
  • SYSC 6.3 - Financial Crime.
  • The Money Laundering Regulations 2007.
  • The Proceeds of Crime Act 2002.
  • The Terrorism Act 2000 (as amended by the Anti-Terrorism Crime and Security Act 2001).

Offences committed can lead to fines and/or imprisonment for firms, managers or employees who fail to manage money laundering risk.