Money Laundering Regulations 2017—monitoring and review
Money Laundering Regulations 2017—monitoring and review

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

  • Money Laundering Regulations 2017—monitoring and review
  • Audit and file reviews
  • Reporting to senior management
  • Dealing with lack of compliance
  • Record keeping

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 require organisations to establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering identified in their organisation-wide risk assessment.

Those policies, controls and procedures must:

  1. be regularly reviewed and updated

  2. include the monitoring and management of compliance with such policies, controls and procedures

This Practice Note considers how organisations can monitor and review the effectiveness of, and compliance with, the anti-money laundering (AML) and counter-terrorist financing (CTF) policies, controls and procedures they have established. It reflects the requirements of the MLR 2017 which came into force on 26 June 2017.

Tools used to monitor and review compliance and effectiveness include:

  1. audit and file reviews

  2. reporting to senior management

  3. identifying lack of compliance or ineffective policies, controls or procedures and formulating solutions

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 monitoring and review.

Audit and file reviews

A system of audit and file reviews can, among other things:

  1. ensure that the organisation's policies and procedures are being adhered to

  2. detect and deter inappropriate behaviour

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