AML/CTF – new Rules and Guidance 
Expires after 90 days
Trevor Hellawell MA (Cantab)
CPD Hours: 1
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