Anti-Money Laundering Policy
This Anti-Money Laundering Policy is designed for a low risk business that wishes to put in place a general policy in order to make staff aware of money laundering, prevent money laundering taking place and what to do should any money laundering activity be suspected. This template has been reviewed in light of the Money Laundering Regulations 2017. This document is also available in the Business Folder.
Money Laundering is the process of moving illegally acquired cash through financial systems so that it appears to come from a legitimate source. Criminals will try to conceal the origin and true ownership of the proceeds of their activities in order to turn the money from “dirty” to “clean”. It is therefore important that businesses have procedures and policies in place to identify and prevent money laundering within their company.
There are three main pieces of legislation that businesses need to be aware of:
• Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
POCA applies to everyone but certain issues related to money laundering only apply to those engaged in activities in the “regulated sector”. If you fall within the “regulated sector” you are required to put in place certain anti-money laundering policies, controls and procedures to anticipate and prevent your business being used by criminals to launder money and fund terrorism. There is more information on both HMRC and the National Crime Agency’s websites as to which businesses fall within the “regulated” sector and what procedures these businesses must follow.
This Anti-Money Laundering Policy contains the following sections:
2. Scope of Policy
3. What is Money Laundering?
4. Money Laundering Reporting Officer
5. Suspicions of Money Laundering (MLRO)
6. Consideration of the Disclosure by the MLRO
7. Customer Identification and Due Diligence
8. Record Keeping
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