Paul Offley, Fine & Country's Compliance Officer shares his top tips on staying compliant with Money Laundering Regulations
During my travels this topic is the one I’m asked about the most, I thought it might be helpful to offer a few tips on helping you to keep compliant.
Tip 1 Make sure you have reviewed your Money Laundering Policy and that the content is still right for your business.
Tip 2 Have all staff got a copy of your Policy, or know where the Policy can be found.
Tip 3 Have you undertaken refresher training with your team within the last 12 months. Really important to be able to demonstrate that your teams have ongoing training on this legislation.
Tip 4 Are you sure your teams understand what is required of them and do they understand what suspicious activity could be?
Tip 5 Review your controls – when did you last check that your Money Laundering processes are working effectively.
Tip 6 Is you registration with HMRC for Money Laundering Supervision up to date. On the Horizon You will have no doubt read about the changes ahead as part of the 4th European Money Laundering Directive which is likely to implemented from the end of June this year. We are waiting for the full details but we do know that there will now be a requirement to undertake due diligence checks on buyers. This potentially means changes to your processes and to your policy document. Start now to make sure you are ready for the change. PEPs – Politically Exposed Persons. Increased focus on the identification of a PEP, a family member of a PEP or a close business associate of a PEP and how agents can demonstrate due diligence in identifying these customer types, and once identified what enhanced due diligence does your firm operate. The Financial Conduct Authority has been asked to provide clarification on the actions business need to take with domestic and foreign PEPs and I will write to you again once I have clarity. However if you do identify a PEP then this should be referred to your Money Laundering Officer before proceeding further. Money Laundering is not horrifically completed, the legislation is there to prevent the integration of ‘dirty money’ such as proceeds of crime or terrorism funds, entering into the legitimate economy. Your role is to help detect and prevent money laundering and terrorist financing activities – your policy, your training, your controls are a vital part of this prevention. Hope this brief note has been of some help, but if you need support with your Money Laundering policy or processes then do please get in touch with me at firstname.lastname@example.org.