The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:
Forthcoming changes: The UK has voted to leave the EU and this will take place on exit day as defined in section 20 of the European Union (Withdrawal) Act 2018. This has implications for law firms. This Practice Note is likely to be affected. It will be updated as and when relevant implementing legislation is published. For more on Brexit, see Practice Notes: Brexit—anti-money laundering and counter-terrorist financing—law firms and Preparing for Brexit—key considerations and action planning—law firms.
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLR 2017) require firms that are subject to the regulations and are also parent undertakings to ensure their policies, controls and procedures apply across all branches and subsidiary undertakings outside the United Kingdom.Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692, reg 20
This Practice Note explains the requirements of the MLR 2017 to apply your anti-money laundering (AML) and counter-terrorist financing (CTF) policies, controls and procedures at group level. It reflects the requirements of the MLR 2017, which came into force on 26 June 2017 and should be read in conjunction with Practice Note: Money Laundering Regulations 2017—systems and controls requirements—law firms.
The MLR 2017 introduce the concept of group-level policies, controls and procedures.MLR 2017, SI 2017/692, reg 20
If your firm is a parent undertaking, you must ensure:
your AML/CTF policies, controls and procedures apply to all your subsidiaries and branches (wherever located in the world), which carry out any of the regulated activities that have brought the firm within the scope
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