The Joint Money Laundering Steering Group (JMLSG) Guidance Notes, [effectively] governing the processes that firms use to carry out anti-money laundering checks in the UK, were updated in December 2001 and revised further in February 2002.

Firms need to consider certain key areas, including; ownership and maintenance of procedures and the degree of discretion given to the business in their interpretation and application; in larger firms, the appointment of a dedicated MLRO (i.e. creating a separate MLRO position, as opposed to the traditional approach of combining it with the Compliance Officer’s other responsibilities) and local Deputy MLROs; the provision of management information for the MLRO; the mechanisms in place for the verification of identity, establishing the legitimacy and ultimate controllers of corporates, the source of funds [and possibly wealth], be that by manual or electronic means, or a combination of both; where ‘data miners’ are used, due diligence on their systems; staff awareness and training (and the assessment of external training providers, where applicable); the monitoring of ‘unusual account activity’; transacting business with non-UK residents and foreign nationals; use of the (so-called) Postal Concession and its availability in future; use of the €15,000 one-off transaction threshold; the issues surrounding the use of electronic payment instruments (in particular, the use of debit cards and BACS); payments to and receipts from third parties; the Bank of England’s ‘terrorist suspects list’ (see our ‘Links’ page), and, finally; the firms own procedures and their implementation.

If you need help to address these issues or help in bringing them to the attention of senior management, contact us.

< go back to Services