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AML/CFT Health Check – United Kingdom Template
The AML/CFT Health Check Tool has been customised to meet the requirements specified in the UK Money Laundering Regulations 2007 for United Kingdom reporting entities.
Our subject matter experts have leveraged and expanded upon the guidance provided in the UK Money Laundering Regulations 2007, the 3rd/4th EU Money Laundering Directive and from JMLSG, as well as, guidance provided by the UK AML/CTF Regulators (Financial Conduct Authority, Financial Services Authority, HMRC and the Office of Fair Trading).
The AML/CFT Health Check for United Kingdom reporting entities contains over 400 out-of-the-box questions, comprising requirement traceability questions, as well as, best practice questions (which can be disabled) across the following categories.
Customer Due Diligence
- Meaning of customer due diligence measures
- Meaning of beneficial owner
- Application of customer due diligence measures
- Ongoing monitoring
- Timing of verification
- Requirement to cease transactions
- Exception for trustees of debt issues
- Simplified due diligence
- Enhanced customer due diligence and ongoing monitoring
- Branches and subsidiaries
- Shell banks, anonymous accounts etc.
- Reliance on others when performing customer due diligence
- Directions where Financial Action Task Force applies counter-measures
Record keeping, procedures and training
- Record keeping
- Policies and procedures
AML/CFT program setup and maintenance – general requirements
- Reporting entity must have AML/CFT programme and AML/CFT compliance officer
- AML/CFT compliance officer
- ML/TF risk assessment
- Employment screening – know your employee
- Independent review of the AML/CFT programme
- Annual AML/CFT report