The firm’s commitment to understanding and minimising our risks in relation to money laundering and terrorist financing and our strengthening of our goals of achieving good ethical business and trading standards are contained within this policy statement.
- Our aim, by having robust policies and procedures and the creation of a compliance culture within the firm, is to prevent money laundering and terrorist financing.
- Protection of the firms’ and staff reputation and integrity.
In order to achieve this policy we have undertaken the following:
- Appointment of the nominated person/money laundering reporting officer (MLRO)
The firm’s MLRO is: MR IHQLAK HUSSAIN
Internal Phone Extension: 0121 327 8316
Mobile Phone Number: 07974569780
Email address: firstname.lastname@example.org
The MLRO is available to discuss any matters relating to the firms policies and procedures relating to the Money Laundering Regulations and helping you understand your obligations.
- Establishment of internal procedures appropriate to the ML regulations to prevent money laundering and terrorist financing.
We have established appropriate and risk-sensitive policies and procedures relating to:
i customer due diligence
iv internal control
v risk assessment and management
vi compliance management, and communication
- Establishment of internal training requirements so all individuals within the firm understand their responsibilities within the firm’s policy and procedures and their wider responsibilities under the UK’s anti money laundering strategy. To this end we will ensure all individuals within the firm are trained at regular intervals for:
- awareness of the relevant legislation
- understanding of their roles and responsibilities under the anti-money laundering regime
- updated on particular threats and alerts for the firm or the profession
- on how to recognise potential suspicious activity
- the firms’ exposure to risk
- the firms’ client due diligence policies and procedures.
- The maintenance and retention of records for five years after ceasing to act for a client relating to:
- clients risk assessments
- client identity and verification
- clients ongoing monitoring
- staff training
- internal reporting
- external reporting
- Making external suspicion reports
The firm through the MLRO has established procedures for assessing internal suspicion reports and on the decision making process. We have established procedures for making external suspicion reports to the National Crime Agency and for the secure retention and storage of internal and external reports.
- Aiding law enforcement
The firm through the MLRO has established procedures for aiding law enforcement agency who obtain money laundering investigation orders against our clients. These procedures relate to the collation and secure retention of the information required and systems to ensure that confidentiality of the client is maintained were necessary.
7 . Individuals commitment to the firm’s policy and procedures
It is important that individuals understand the compliance culture and their roles and responsibilities that is placed upon them. Individuals should understand that penalties imposed including fines and imprisonment applies to individuals as well as the firm.
So individuals should:
- ensure that they understand the firms policy and procedures contained in this document
- ensure that during the course of your work for the firm you don’t turn a blind eye to the obvious. If you have doubts over the legitimacy of a transaction or event then you must follow procedures to discuss the situation or make an internal suspicion activity report. It is only by following these procedures are you protected from the possible penalties contained within the legislation
- you must however remember that you should not speculate as to whether a crime has been committed. In order for a report to be made there must be reasonable suspicion that a crime has been committed, the client intended for a crime to be committed and there must be proceeds of that crime. An innocent error is not a crime, these has to be an element of intent
- we are not required to be an investigator that is the role of law enforcement, neither are we judge or jury
- remember that ‘tipping off’ is an offence under the legislation. Don’t discuss what you may or may not report with the client and don’t make reports the topic of general conversation within the office.