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PRECEDENTS
How to use this test These questions are designed to test your understanding after your attendance at training on anti-money laundering, counter-terrorist financing and 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 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(b) Soliciting or accepting a bribe(c) Employees taking money from customer accounts and using it to fund crime 2. What is terrorist financing? (a) Terrorising customers 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 are red flags? (a) Warning signs of money laundering, terrorist financing and proliferation financing(b) A formal label attached to risky customers by the suspicious activity report (SAR)(c) An indication that a customer is low risk 4.
NEWS
The European Banking Authority (EBA) has announced that, starting from May 2024, supervisors across the EU will be able to report names of natural persons to EuReCA, its EU central database on anti-money laundering (AML) and countering the financing of terrorism (CFT).
NEWS
The European Union hosted the Africa Joint Group of the Financial Action Task Force (FATF) in Brussels from 2 to 12 September 2024. The Africa Joint Group is one of the four divisions of the FATF International Cooperation and Review Group, in which progress of jurisdictions with strategic deficiencies regarding anti-money laundering and countering the financing of terrorism (AML/CFT) is examined. The EU recognises AML/CFT as a priority both to ensure the security of its citizens and to preserve the integrity of the international financial system. The key elements in this process are effective AML/CFT policies, in line with international standards such as those set by the FATF. As part of this effort, the EU also provides technical assistance worldwide to a wide range of countries, including in Africa, which have requested such assistance under the Global Facility on AML/CFT.
NEWS
The Wolfsberg Group has updated its ‘Principles for auditing a financial crime risk management programme for effectiveness under the Wolfsberg Factors’. Originally published in 2019, the Group says the Factors should underpin any financial institution’s anti-money laundering/counter terrorist financing (AML/CFT) programme, and that internal audit can assist financial institutions in the fight against financial crime by measuring financial crime risk management outcomes using the Factors.
PRACTICE NOTES
This Practice Note is for those advising financial services firms on the UK’s anti-money laundering (AML) and counter-terrorist financing (CTF) legal and regulatory requirements for ongoing monitoring as part of customer due diligence (CDD), also known as ‘Know your customer’ (KYC), under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs). This Practice Note addresses the operation, governance and oversight of ongoing monitoring after a customer has been onboarded. It consolidates the legal requirements of the MLRs, the regulatory requirements and guidance published by the Financial Conduct Authority (FCA), and guidance published by the Joint Money Laundering Steering Group (JMLSG) on CDD ongoing monitoring. It also addresses transaction monitoring as a component of ongoing monitoring, and identifies common failings in ongoing monitoring and transaction monitoring drawn from FCA enforcement action and supervisory publications. It forms part of a wider practical guidance series addressing AML/CTF legal and regulatory requirements for financial services firms, see: Anti-money laundering and counter-terrorist financing (AML/CTF)—overview. References to regulations in
PRACTICE NOTES
This Practice Note is for those advising financial services firms on how to comply with the UK’s anti-money laundering (AML), counter-terrorist financing (CTF), and countering the financing of proliferation of weapons of mass destruction (CPF) legal and regulatory record-keeping requirements for customer due diligence (CDD), also known as ‘Know your customer’ (KYC), and the data protection issues set out in Regulations 40 and 41 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs). This Practice Note consolidates the legal requirements of the MLRs, the regulatory requirements and guidance published by the Financial Conduct Authority (FCA), and guidance published by the Joint Money Laundering Steering Group (JMLSG) on CDD record-keeping. It also draws on guidance published for the insurance and banking industries by the International Association of Insurance Supervisors (IAIS) and the Basel Committee on Banking Supervision (BCBS). This Practice Note addresses the CDD record-keeping legal and regulatory requirements applicable to financial services firms that are in scope of the MLRs such as credit
PRACTICE NOTES
This Checklist is for those advising financial services firms in scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs), including credit and financial institutions, cryptoasset exchanges and custodian wallet providers. It addresses the legal requirements on financial services firms’ reliance on third parties to apply customer due diligence (CDD) measures, also referred to as know your customer (KYC) measures, under Regulation 39 of the MLRs and the associated regulatory requirements and guidance published by the Financial Conduct Authority (FCA). It also refers to industry guidance published by the Joint Money Laundering Steering Group (JMLSG), and incorporates relevant guidance for the insurance and banking sectors issued by the International Association of Insurance Supervisors (IAIS) and the Basel Committee on Banking Supervision (BCBS). References to regulations in this Practice Note are to the MLRs. This Checklist is one of a series addressing AML/CTF legal and regulatory requirements on financial services firms, see: Anti-money laundering and counter-terrorist financing (AML/CTF)—overview. Key
PRACTICE NOTES
The Financial Services Enforcement Database incorporates detailed information on all substantive FCA and PRA Final Notices and, where available, Decision Notices from 2014 onwards. The Database may be searched and filtered by regulatory rule breach (including SYSC), keyword (including ‘Anti-money laundering (AML) systems and controls’ and ‘Customer due diligence (CDD)’), sector, date, seriousness, aggravating and mitigating factors, financial penalty, and other actions such as referrals to the Upper Tribunal. The Database may also be searched by breaches of specific regulations in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs). This Practice Note is for those advising financial services firms on how to comply with the UK’s anti-money laundering (AML), counter-terrorist financing (CTF), and countering the financing of proliferation of weapons of mass destruction (CPF) legal and regulatory requirements to conduct customer due diligence (CDD), also referred to as ‘know your customer’ (KYC), set out in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692
PRACTICE NOTES
This Checklist is for those advising financial services firms on how to comply with the UK’s anti-money laundering (AML), counter-terrorist financing (CTF), and countering proliferation financing (CPF) legal and regulatory framework. It forms part of a wider series addressing the requirements to conduct customer due diligence (CDD), sometimes referred to as ‘know your customer’ or ‘KYC’, set out in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs) and the associated guidance published by the Financial Conduct Authority (FCA) and the Joint Money Laundering Steering Group (JMLSG). It also considers FCA enforcement action for EDD failures. This Checklist specifically addresses the requirements to conduct enhanced customer due diligence (EDD), both in general higher risk situations and also in specific circumstances involving unusual transactions, FATF call for action countries and correspondent relationships. For information on applying EDD to politically exposed persons, see: AML/CTF checklist—politically exposed persons (PEPs) for financial services firms. For further checklists on CDD requirements, see: Anti-money laundering and counter-terrorist
PRACTICE NOTES
The Financial Services Enforcement Database incorporates detailed information on all substantive FCA and PRA Final Notices and, where available, Decision Notices from 2014 onwards. The Database may be searched and filtered by fields including regulator, rule/legislation breach, keyword—including ‘Anti-money laundering (AML) systems and controls’ and ‘Customer Due Diligence (CDD)’, sector, date, financial penalty, aspects of financial penalty analysis, outcomes including redress and prohibition orders, and other actions such as referrals to the Upper Tribunal. This Practice Note is for those advising financial services firms on how to comply with the UK’s anti-money laundering (AML), counter-terrorist financing (CTF) and countering the financing of proliferation of weapons of mass destruction (CPF), legal and regulatory framework. This Checklist is one of a wider series addressing the requirements to conduct customer due diligence (CDD), sometimes referred to as ‘know your customer’ (KYC), set out in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs) and the associated regulatory requirements and guidance published by the Financial Conduct Authority
PRACTICE NOTES
This Checklist is for those advising financial services firms in scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRS) (including credit and financial institutions, cryptoasset exchange and custodian wallet providers) on compliance with the UK’s anti-money laundering (AML) and counter-terrorist financing (CTF) legal and regulatory framework.  It specifically addresses the legal and regulatory requirements for Enhanced Due Diligence (EDD) measures where the firm identifies that a customer or beneficial owner, business relationship or transaction involves ‘politically-exposed persons’ (PEPs), their ‘family members’ or their ‘known close associates’, commonly referred to as ‘relatives and close associates’ (RCAs). It considers the requirements under Regulation 35 of the MLRS and the regulatory requirements of the Financial Conduct Authority (FCA). It incorporates regulatory guidance set out by the FCA: Finalised Guidance: The treatment of politically exposed persons for AML purposes (FG25/3); the FCA’s Financial Crime Guide (FCG) and the FCA’s multi-firm review on the treatment of PEPs. It further incorporates guidance published by the Joint Money
CHECKLISTS
This timeline outlines developments from 1 January 2024 onwards relating to the anti-money laundering (AML), counter-terrorist financing (CTF), and counter-proliferation financing (CPF) legal and regulatory regimes applicable to financial services firms—from an EU perspective. It shows the developments and implementation history of the European AML, CTF and CPF legislative framework. It also includes supranational AML/CTF/CPF developments from the Financial Action Task Force (FATF), Basel Committee on Banking Supervision (BCBS), International Association of Insurance Supervisors (IAIS), International Organization of Securities Commissions (IOSCO), Egmont Group of Financial Intelligence Units (FIUs) and the Wolfsberg Group. For further information on the EU AML/CTF legal and regulatory regime, see the Financial crime and sanctions (EU Law)—overview which includes Practice Notes: AMLA—EU Authority for AML/CTF, AMLA—direct supervision of qualifying financial services firms, EU Sixth Money Laundering Directive (MLD6) and EU Recast Second Wire Transfer Regulation (Recast WTR2)—cryptoasset transfers. For UK developments, see: AML/CTF/CPF—timeline of UK legal and regulatory developments for financial services and Anti-money laundering and counter-terrorist financing (AML/CTF)—overview. 2026 Date Source Document Description 6