AML/CTF – new Rules and Guidance [2021]

This course is essential for anyone taking on anti-money laundering duties within a firm, and a useful refresher for those who already hold this crucial responsibility.

• The relevant legislation in the Proceeds of Crime Act and Terrorism Act
• The NCA and reporting of suspicions
• The penalties for getting it wrong
• The Money Laundering Regulations 2017 as amended by the 2019 and 2020 Amendment Regulations
• New Legal sector Affinity Group guidance (LSAG Jan 2021) on how to comply with the Regulations, in particular
  • Risk assessments – firm-wide (PWRAs) and client and matter-based
  • Policies, controls and procedures (PCPs)
  • Due diligence including ongoing CDD and enhanced CDD
  • Capturing client information
  • New duties in relation to the beneficial owners
  • Identifying and evidencing the source of funds AND the course of wealth
  • What is a PEP?
  • Technology – uses and considerations
  • Record keeping
  • Data protection
• Training - how up to date are your staff?
• No point in having procedures if your staff ignore them
• The role and responsibilities of the MLCO & MLRO
• The key duty – ongoing monitoring

Key points to take away

• Full understanding of the nature of the financial issues we face
• The importance of undertaking thorough CDD – even if it feels un-necessary
• What information do we need on the ultimate beneficial owner?
• Source of WEATLH enquiries, as well as source of funds
• Ongoing Monitoring – the key to success
• Record everything – if in doubt, write it down