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 financing compliance 3.1 The firm itself is primarily responsible for compliance with MLR 2017, including all systems and control requirements. 3.2 [While the firm 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 following table:

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

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,

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

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

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

The law and red flags Circle the correct answer. col style="width: 50%;"> 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 have, or anyone else has, made a SAR

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. How do you need to act when looking

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).

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.

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.

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