What are the Money Laundering Regulations 2017?
In conjunction with the implementation of the Fourth EU Money Laundering Directive, the UK has consulted upon and implemented the Money Laundering Regulations 2017 (MLR 2017), which are complemented by the Joint Money Laundering Steering Group (JMLSG) and Financial Conduct Authority (FCA) guidance.
What has changed following the implementation of MLR 2017?
The key change in the regulations is the enhancement of the risk-based approach.
The previous legislation referred to risk 39 times compared to 149 times in the new legislation.
Moving to a wholly risk-focused approach involves understanding risk and assessing it appropriately before deciding on the measures your Firm will take to manage the risk. This change must be reflected in your procedures, particularly the risk assessment process and scoring methodology, as well as through training programmes designed to educate your employees to understand and embody these measures.
How CCL can help
With our skills and experience in international AML/CTF standards, as well as the UK, we will work with you to help your Firm adopt the right approach to MLR 2017, as well as helping you gain assurance on your compliance to the new regime through the following support services:
- Perform a MLR 2017 compliance health check
- Assess your risk-based approach, including business risk assessment, customer risk assessment and ongoing due diligence and monitoring arrangements
- Update your policies and procedures
- Analyse your PEP customers to assess if and how the new regime impacts them
- Assess and advise on your correspondent relationships
- Provide advice on the new regime and operational implementation of appropriate controls
- Advise on the equivalence of 3rd party controls
- Review your Suspicious Activity Reporting (SAR) process
- Conduct workshops with employees that “need to know”
- Deliver business-wide training