Money Laundering Regulations 2017—group level policies, controls and procedures

The following Risk & Compliance practice note provides comprehensive and up to date legal information covering:

  • Money Laundering Regulations 2017—group level policies, controls and procedures
  • Group-level policies under MLR 2017
  • Identifying relevant group members
  • Parent and subsidiary undertakings
  • Do the requirements apply to your own organisation's parent undertaking?
  • Dealing with local law requirements
  • Subsidiary undertakings and branches in a third country
  • Sharing client due diligence information with other parts of a group
  • Managing and communicating your group-level policies, controls and procedures

Money Laundering Regulations 2017—group level policies, controls and procedures

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLR 2017), as amended, require organisations that are subject to the MLR 2017 and are also parent undertakings to ensure their policies, controls and procedures apply across all branches and subsidiary undertakings outside the UK.

This Practice Note explains the requirements of the MLR 2017, as amended, 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, as amended, and should be read in conjunction with Practice Note: Money Laundering Regulations 2017—systems and controls requirements.

This Practice Note provides guidance which is of general application. You should check whether the MLR 2017 contain additional or varied requirements for your sector and whether your regulatory body has any additional, sector specific requirements in relation to group level policies, controls and procedures.

Group-level policies under MLR 2017

The MLR 2017 introduce the concept of group-level policies, controls and procedures.

If your organisation is a parent undertaking, you must:

  1. 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 organisation within the scope of the MLR 2017

  2. establish and maintain throughout

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