1 General information Person(s) conducting audit [Insert name(s) and role(s) of auditor(s)] Internal or external auditor(s) ☐ Internal☐ External Dates of audit From [insert date] to [insert date] Firm-wide or targeted audit ☐ Firm-wide☐ Targeted [State precisely what was targeted, eg property transactions funded by cryptoassets] [Office(s) covered by the audit] [[Insert details of offices covered by this audit]] 2 Executive summary [Insert executive summary of report findings] [[Insert summary of recommendations, eg:] Importance Number of recommendations Critical [Insert number of recommendations from section 5 categorised as critical] Important [Insert number of recommendations categorised as important] Housekeeping [Insert number of recommendations categorised as ‘Housekeeping']] 3 Scope of audit 3.1 This audit has been carried out to: 3.1.1 examine and evaluate the adequacy and effectiveness

This schedule of recommendations can be used by the independent audit function to set out its recommendations following audit of the organisation’s anti-money

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended, require organisations to establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering, terrorist financing and proliferation financing identified in their organisation-wide risk assessment. Those policies, controls and procedures must: • be regularly reviewed and updated • include the monitoring and management of compliance with, and the internal communication of, 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), counter-terrorist financing (CTF) and counter-proliferation financing policies, controls and procedures they have established. It reflects the requirements of the MLR 2017, as amended. Tools used to monitor and review compliance and effectiveness include: • audit and file reviews • reporting to senior management • identifying lack of compliance or ineffective policies, controls or procedures and formulating solutions This Practice Note provides guidance which is of general application.

This Practice Note sets out when organisations must appoint a nominated officer (sometimes referred to as a money laundering reporting officer or MLRO), the duties of the nominated officer and practical steps nominated officers can take to fulfil their role. It reflects the requirements of the Money Laundering Regulations 2017, SI 2017/692 (MLR 2017), as amended. It provides guidance which is of general application. You should check whether your regulatory body has any additional, sector specific requirements in relation to nominated officers. What is a nominated officer? A nominated officer is a person who is nominated to receive and consider suspicious activity reports (SARs) under the Terrorism Act 2000 (TA 2000) and the Proceeds of Crime Act 2002 (POCA 2002). They are also expected to make external SARs to the National Crime Agency (NCA). The nominated officer is not the same as the MLCO, ie the board-level person appointed as the officer responsible for the organisation’s compliance with the MLR 2017—see section: Internal relationships. Do you have to appoint a nominated officer? Not

1 Nominated officer details Name of organisation [Insert name] Name of nominated officer [Insert name] Reports to [Insert name] Full time/part time ☐ Full time☐ Part time Details of any other roles held within the organisation [Insert details] Date appointed by the organisation [Insert date] 2 Role summary 2.1 To act as the nominated officer appointed in accordance with the Money Laundering Regulations 2017 (MLR 2017) for [name of organisation]. 2.2 To receive and review internal suspicious activity reports (SARs) and determine whether they give rise to knowledge or suspicion (or reasonable grounds for knowledge or suspicion) that a person is engaged in money laundering, terrorist financing or proliferation financing. 2.3 To decide whether to report suspicious activity to the National Crime Agency (NCA), to make external SARs where necessary and be the main point of contact with the NCA. 2.4 To ensure systems and controls are in place to enable the organisation, including its managers and employees, to comply with their obligations under: 2.4.1 the Proceeds of Crime Act 2002 (POCA 2002); 2.4.2 the MLR 2017; 2.4.3 the Terrorism Act 2000 (TA 2000); 2.4.4 [the Bribery Act 2010 (BA 2010);] 2.4.5 [fraud risk management requirements;] 2.4.6 [the sanctions regime;]

1 Nominated officer details Name of firm [Insert name] Name of nominated officer [Insert name] Reports to [Insert name] Full time/part time ☐ Full time☐ Part time Details of any other roles held within the firm [Insert details] Date appointed by the firm [Insert date] 2 Role summary 2.1 To act as the nominated officer appointed in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) for [name of firm]. 2.2 To receive and review internal suspicious activity reports (SARs) and determine whether they give rise to knowledge or suspicion (or reasonable grounds for knowledge or suspicion) that a person is engaged in money laundering, terrorist financing or proliferation financing. 2.3 To decide whether to report suspicious activity to the National Crime Agency (NCA), to make external SARs where necessary and be the main point of contact with the NCA. 2.4 To ensure systems and controls are in place to enable the firm, including its managers and employees, to comply with their obligations under: 2.4.1 the Proceeds of Crime Act 2002 (POCA 2002); 2.4.2 the MLR 2017; 2.4.3 the Terrorism Act 2000 (TA 2000);

1 General information Date of this report [Insert date] Date of last report [Insert date] Name of person submitting report [Insert name] 2 Action points arising from last nominated officer report Action point Person responsible Status [Action point] [Identify person responsible for this action point (may or may not be the nominated officer)] [Status] [Action point] [Identify person responsible for this action point (may or may not be the nominated officer)] [Status] [Action point] [Identify person responsible for this action point (may or may not be the nominated officer)] [Status] 3 Executive summary This report sets out the following matters: 3.1 governance arrangements—see section 4.1; 3.2 summary of business operations—see section 4.2; 3.3 report on operation of AML, CTF and counter-proliferation financing systems and controls—see section 4.3; conclusions and recommendations—see section 5. 4 Report 4.1 Governance 4.1.1 Board-level money laundering compliance officer (MLCO)—details, functions and resources (a) Details Name [Insert] [ Duration or date of appointment ] [[Insert duration or date, note that if you rotate the MLCO role around several individuals, state when the current MLCO was appointed and when their appointment is expected to expire.]] (b) Functions and resources The MLCO is the [insert status in a way that denotes board-level or equivalent

This Practice Note sets out when firms must appoint a nominated officer (sometimes referred to as a money laundering reporting officer or MLRO), the duties of the nominated officer and practical steps nominated officers can take to fulfil their role. It reflects the requirements of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. This Practice Note reflects Legal Sector Affinity Group (LSAG) AML guidance. It also reflects key findings contained in the SRA’s various reports and publications (SRA: Research and publications—Money laundering), together with SRA guidance Money Laundering Governance: Three Pillars of Success. Where the SRA’s Three Pillars guidance refers to ‘AML officers’, this means the nominated officer and/or Money Laundering Compliance Officer (MLCO). For more on the MLCO, see Practice Note: Money laundering compliance officer—law firms. What is a nominated officer? The nominated officer is the person nominated to receive and consider suspicious activity reports (SARs) under the Terrorism Act 2000 (TA 2000) and the Proceeds of Crime Act 2002 (POCA

As part of your customer due diligence (CDD) measures, you must conduct ongoing monitoring of your business relationships. This Practice Note explains the ongoing monitoring requirements contained in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. It 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 ongoing monitoring. Counter-proliferation financing is an established component of the anti-money laundering (AML) and counter-terrorist financing (CTF) regime. Requirements in relation to counter-proliferation financing were introduced through amendments to the MLR 2017 and include in relation to systems and controls, risk assessment, etc. No specific counter-proliferation financing requirements were added in relation to CDD, and existing CDD provisions in the MLR 2017 were not amended to include mention of proliferation financing. Therefore, counter-proliferation financing is not covered in this Practice Note. For more information, see Practice Note:

As part of your client due diligence (CDD) measures, you must conduct ongoing monitoring of your business relationships. This Practice Note explains the ongoing monitoring requirements contained in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. Counter-proliferation financing is an established component of the anti-money laundering (AML) and counter-terrorist financing (CTF) regime. Requirements in relation to counter-proliferation financing were introduced through amendments to the MLR 2017 and include in relation to systems and controls, risk assessment, etc. No specific counter-proliferation financing requirements were added in relation to CDD, and existing CDD provisions in the MLR 2017 were not amended to include mention of proliferation financing. Therefore, counter-proliferation financing is not covered in this Practice Note. For more information, see Practice Note: Counter-proliferation financing—CPF—the basics. What is ongoing monitoring? Ongoing monitoring is made up of two limbs: • scrutinising transactions throughout the course of the business relationship (including, where necessary, the source of funds) to ensure they are consistent with what you know about

Individuals who have, or have had, a high political profile, or hold, or have held, public office, can pose a higher money laundering risk to firms as their position may make them vulnerable to corruption. This risk also extends to members of their immediate families and to known close associates. Politically exposed person (PEP) status itself does not, of course, incriminate individuals or entities, but it does put the client or the beneficial owner into a higher risk category. You must apply enhanced due diligence (EDD) measures and enhanced ongoing monitoring where you have determined that the client/potential client is a PEP, or a family member or known close associate of a PEP. When this requirement is triggered, the requirement to conduct EDD is mandatory but you can take a risk-based approach when determining the nature and extent of the EDD measures to apply. This Practice Note explains provisions relating to PEPs, including their purpose, what a PEP is, and requirements in relation to identifying and risk assessing PEPs. It also contains guidance

This Practice Note explains the regulatory requirements relating to anti-money laundering (AML), counter-terrorist financing (CTF) and counter-proliferation financing record keeping as set out in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. 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 record keeping. If you are subject to the MLR 2017, you must establish and maintain appropriate and risk-sensitive policies and procedures relating to record keeping. Record keeping is an essential component of the AML, CTF and counter-proliferation financing regime because it: • evidences your compliance with regulatory obligations, and • assists law enforcement agencies in conducting financial investigations Records you must keep Record keeping requirements are not subject to the risk-based approach and therefore there is no room for subjective assessment of the extent to which you should comply. You must keep the following records: • a copy of customer