Commentary

A7.120 Policies, controls and procedures

Administration and compliance

A7.120 Policies, controls and procedures

A7.120 Policies, controls and procedures

In order to prevent activities relating to money-laundering and terrorist financing, a 'relevant person' (A7.115) must establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering and terrorist financing identified in any risk assessment undertaken by the relevant person1. They must also regularly review and update those policies, controls and procedures, and must maintain a record of them in writing (as well as a record in writing of any changes to them, and any steps taken to communicate the policies, controls and procedures or any changes to them within the business)2. They must, where relevant, be communicated to their branches and subsidiaries located outside the United Kingdom3.

The policies, controls and procedures must be proportionate with regard to the size and nature of the relevant person's business (and so taking into account is risk assessment under regulation 18, see A7.116, as well as any guidance issued by the Financial Conduct Authority or any other supervisory authority or appropriate body and approved by the Treasury) and must be approved by its senior

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