AML Policies and Controls

Posted on by Know Your Compliance
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27
Oct

Section 19(1) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR) references AML policies and controls. It defines what measures and procedures a ‘relevant person’ must have in place to comply with the Regulations.

What are the MLR Policies and Controls?

Section 19(1)(a) requires those with MLR obligations to “establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering and terrorist financing“.

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The AML policies and controls required by the Regulations are extensive and are covered in detail between Sections 21-40 of the MLR. The policy and control criteria for money laundering prevention fall into 5 main categories: –

  • Risk Assessment & Management
  • Internal Controls:
  • Customer Due Diligence:
  • Record Keeping:
  • Compliance Monitoring & Audits:

Oversight of the AML Policies and Controls

The policies and controls discussed above must be reviewed and updated regularly as well as being maintained in writing. Records should be kept detailing any changes made to the policies and controls and the steps taken to disseminate and communicate the policy content and measures to employees.

It is important that the AML policies, controls and procedures developed by those who must comply with the MLR are proportionate to the size, scope and nature of the business. Before the measures and policies can be implemented, they must also be reviewed and approved by senior management or the business owner.

AML Training for Employees

Clipart of four people in a training sessionOne of the many requirements under the MLR is that employees are trained to know and understand the requirements and their obligations as they relate to money laundering prevention. All employees should be made aware of the law and Regulations relating to money laundering, terrorist and proliferation financing.

Training and access to resources and information should be ongoing and written records must be kept for all training sessions. It is also important to test an employees knowledge and understanding so that any gaps or inaccuracies can be addressed.