At the end of November 2021 the SRA produced a useful report with a summary of what it expects from the firm it regulates and conclusions from the firms it had reviewed that year.
Here is a link to it. Below we have summarised the main points. If you have questions about AML please contact us by filling in the form below. We have a number of AML services to help firms which you will find in the Compliance services accessed from the top of this screen (menu on the mobile view) or just ask us. We will bespoke to your needs.
The main pints of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the regulations) are summarised by the SRA as:
The SRA have produced guidance on some of these areas :
The principal people responsible for compliance are:
Every person in a firm has a responsibility to make sure that it is not used for money laundering, and that relevant reports are made of any suspicious activity. MLCOs and MLROs form the keystone of the firm’s efforts. The success of the firm’s AML regime as a whole is likely to depend on suitably knowledgeable, skilled and authoritative people holding these roles.
Below, the SRA set out what they consider to be the three main attributes a successful MLCO or MLRO should have:
The MLRO & MLCO should ask themselves if they have the authority, independence & resources to properly carry out their roles.
Between April & September 2021 the SRA reviewed 50 firms. It found that largely the MLRO & MLCO had sufficient authority & Independence. However with regard to adequate resources the picture was more patchy:
The SRA recommend that a deputy be appointed. This makes a lot of sense as it adds resilience - no single point of failure.
Our own findings
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