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GLOSSARY
American Municipal Bond Assurance Corporation—a monoline insurer.
NEWS
The Arbitration and Mediation Center of Armenia (AMCA) has announced that the institution has adopted its first set of arbitration rules. The rules have been scrutinised and created by national and international arbitration experts and will assist in making Armenia a favourable seat of arbitration
NEWS
The Financial Markets Standards Board (FMSB) has published for consultation, a draft template FMSB Standard entitled ‘Standard for Client Onboarding: Documentation and Processes’. The proposed Standard would be applicable to firms when onboarding or reviewing client files under UK anti-money laundering (AML) requirements around know-your-customer (KYC) (or customer due diligence (CDD)).  The proposals are intended to apply to all client industries, however, the draft Standard places specific focus on financial institutions including asset managers and funds. Responses are requested by 3 May 2024.
PRECEDENTS
Please click for an Excel version of this register. General Course name/description [Insert course name/description] Reason for training(routine update/induction/change in
PRECEDENTS
1 Introduction to the policy 1.1 [Organisation name] is required to put in place appropriate systems and controls to combat money laundering, terrorist financing and proliferation financing under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. 1.2 For more details on MLR 2017, see section 10. 2 Scope and application 2.1 This policy contains the procedures we have developed to comply with MLR 2017, as amended. 2.2 This policy applies to all[ our offices], employees, officers, consultants, contractors and to other workers including agency workers, casual workers[, volunteers] [, interns] and home workers. 2.3 All staff must be familiar with this policy and comply with its terms. 2.4 This policy does not form part of any contract of employment and we may amend it at any time. 3 Responsibility for AML, CTF and counter-proliferation financing compliance 3.1 The organisation itself is primarily responsible for compliance with MLR 2017, including all systems and control requirements. 3.2 [While the organisation is primarily responsible for compliance with MLR 2017, we have appointed a money-laundering compliance officer (MLCO) and a nominated officer, as shown in the table below:
PRECEDENTS
UNDER REVIEW: On 6 August 2026, the Solicitors Regulation Authority (SRA) updated the SRA Sectoral Risk Assessment - Anti-money laundering, terrorist financing, proliferation financing and sanctions. For further information, see LNB News 06/08/2026 17. We are in the process of reviewing this content. 1 Introduction to the policy 1.1 [Firm name] is required to put in place appropriate systems and controls to combat money laundering, terrorist financing and proliferation financing under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. 1.2 For more details on MLR 2017, see section 10. 2 Scope and application 2.1 This policy contains the procedures we have developed to comply with MLR 2017, as amended. 2.2 This policy applies to all [our offices, ]employees, officers, consultants, contractors and to other workers including agency workers, casual workers[, volunteers] [, interns] and home workers. 2.3 All staff must be familiar with this policy and comply with its terms. 2.4 This policy does not form part of any contract of employment and we may amend it at any time. 3 Responsibility for AML, CTF and counter-proliferation
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The law and red flags Question Multiple choice answers 1. What is money laundering? (a) The process through which proceeds of crime and their true origin and ownership are changed so that the proceeds appear legitimate 2. What is terrorist financing? (b) Providing/collecting funds from legitimate or illegitimate sources for terrorist acts [3. What is proliferation financing?] [(c) Providing funds or financial services for use, in whole or in part, in the manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer, stockpiling of, or otherwise in connection with the possession or use of, chemical, biological, radiological or nuclear weapons] 4. What are red flags? (a) Warning signs of money laundering, or terrorist financing [or proliferation financing] 5. How do you need to act when looking out for red flags and other signs of money laundering or terrorist financing [or proliferation financing]? (c) Like a reasonable person (with the same qualifications, knowledge and experience as you) 6. Failure to disclose can result in what penalty? (c) Five years’ imprisonment, a fine or both 7. What can be a defence to the offence of failure
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How to use this test These questions are designed to test your understanding after your attendance at training on anti-money laundering and counter-terrorist financing.[ It also covers counter-proliferation financing.] After you have completed this test, please return it to [insert name]. General Name of person completing test [Insert name] Role [Insert role] Date [Insert date] Circle the correct answer. The law and red flags Question Multiple choice answers 1. What is money laundering? (a) The process through which proceeds of crime and their true origin and ownership are changed so that the proceeds appear legitimate(b) Soliciting or accepting a bribe(c) Employees taking money from client accounts and using it to fund crime 2. What is terrorist financing? (a) Terrorising clients by demanding money(b) Providing/collecting funds from legitimate or illegitimate sources for terrorist acts(c) Providing/collecting funds from illegitimate sources for terrorist acts [3. What is proliferation financing?] [(a) Bribing a foreign public official] [(b) Providing funds or financial services for use, in whole or in part, for the purpose of acts of terrorism] [(c) Providing funds or financial services for use, in whole or in part, in the manufacture,
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Scenario A: Politically exposed person You have been approached by a new client with instructions to assist in the purchase of a football club. The client is a high net worth individual who made his fortune in the mining industry in an emerging market. He then moved into politics before choosing to pursue some business interests. In accordance with the firm’s policy, enhanced due diligence (EDD) has been carried out and his politically exposed person (PEP) status was highlighted. The issue of source of funds was raised and the client responded to say that the acquisition was to be funded out of the proceeds of sale of one of his former mining businesses. During the course of the matter you have found the client to be a difficult character who constantly tries to change his instructions with no logical explanation. It has also been brought to your attention by a junior lawyer that in a recent news article the client had been accused of bribery in obtaining the mining concessions on which his
PRECEDENTS
Scenario A: Politically exposed person You have been approached by a new client with instructions to assist in the purchase of a football club. The client is a high net worth individual who made his fortune in the mining industry in an emerging market. He then moved into politics before choosing to pursue some business interests. In accordance with the firm’s policy, enhanced due diligence (EDD) has been carried out and his politically exposed person (PEP) status was highlighted. The issue of source of funds was raised and the client responded to say that the acquisition was to be funded out of the proceeds of sale of one of his former mining businesses. During the course of the matter you have found the client to be a difficult character who constantly tries to change his instructions with no logical explanation. It has also been brought to your attention by a junior lawyer that in a recent news article the client had been accused of bribery in obtaining the mining concessions on which
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1 General information Review period [Insert review period] Date of review [Insert date] Person(s) conducting review [Insert name(s)] 2 Data Criteria In the last [insert period, eg quarter] Over the last 12 months Total number of Suspicious activity reports (SARs) received [Insert number] [Insert number] Number of SARs relating to money laundering, terrorist financing or proliferation financing [Insert number] [Insert number] Number of SARs relating to money laundering, terrorist financing or proliferation financing reported to the National Crime Agency (NCA) [Insert number] [Insert number] Number of SARs relating to money laundering, terrorist financing or proliferation financing reported to the NCA requiring consent/a defence (DSARs) [Insert number] [Insert number] Number of DSARs for which consent has been granted [Insert number] [Insert number] Number of DSARs for which consent has been refused [Insert number] [Insert number] Number of DSARs reported to NCA for which a decision on consent is awaited [Insert number] [Insert number] Number of SARs relating to money laundering, terrorist financing or proliferation financing not reported to the NCA [Insert number] [Insert number] Number of superSARs received [Insert number] [Insert number] Number of CDD company information discrepancy reports made [Insert number] [Insert number] Number of Politically exposed persons (PEPs) added to the PEP central list [Insert number] [Insert number] 3 Review and findings Have you performed a fresh
PRECEDENTS
The law and red flags Circle the correct answer. Question Multiple choice answers 1. What is money laundering? (a) The process through which proceeds of crime and their true origin and ownership are changed so that the proceeds appear legitimate 2. What is terrorist financing? (b) Providing/collecting funds from legitimate or illegitimate sources for terrorist acts 3. What are red flags? (a) Warning signs of money laundering, terrorist financing and proliferation financing 4. How do you need to act when looking out for red flags and other signs of money laundering, terrorist financing and proliferation financing? (c) Like a reasonable person (with the same qualifications, knowledge and experience as you) 5. Failure to disclose can result in what penalty? (c) Five years’ imprisonment, a fine or both 6. What can be a defence to the offence of failure to disclose? (c) Making a SAR to the nominated officer 7. Which Act establishes a number of money laundering offences? (a) Proceeds of Crime Act 2002 (POCA 2002) 8. What offence would you be committing if you disclose that you