Systems and Controls
Identify complex / unusually large transactions
Prevent use of anonymity granting products
Perform customer due diligence
Appoint mlro
Customer record keeping for 5 years
ML compliance monitoring
Make employees aware of ML regulations
Risk-Based approach
Target efforts where risk is highest
Watch for unusual transactions
Keep customer due diligence up to date
Customer Due Diligence
Test riskiness of client to see amount of DD
Always at the start of a business relationship
When there's unusual transaction
When suspicious
To new and old clients on a risk sensitive basis
Identify beneficial owner
Monitor throughout relationship
Reporting
Suspicious activity reports
Have an MLRO to report to
Failure to report is an offence
When reports made, they are protected
Report as soon as possible
MLRO
Significant responsibility
Senior person
Absences covered
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