Anti-Money Laundering Programme

NotesQuizPaper exam

The MLRO is responsible for setting up the anti-money laundering programme

The following is required
  1. Dedicated Resources

    • An MLRO in place

    • The MLRO has appropriate knowledge, experience and responsibility

  2. Written Policies and Procedures

    The procedures should use available technology and identify risk factors - items to look for when detecting money laundering

    • These risk factors could include
      • Secrecy with a transaction

      • Transactions through several jurisdictions or financial institutions without any apparent purpose

      • Using central bank or government-owned banks as the source of funds

      • A rapid increase/decrease in a balance, not explained by fluctuations in the underlying market value of investments held

      • Frequent or excessive use of funds/wire transfers in or out of an account

      • Repeated deposits or withdrawals just below the monitoring and reporting threshold on or around the same day

      • A pattern that after a deposit or wire transfer the same (or similar) amount is wired to another financial institution (especially one that is offshore).

      • A frequent clearing out of an account for purposes other than maximising the value of the funds held in the account

  3. Comprehensive Coverage

    • All aspects of a company's business, particularly those that
      have contact with customers should be covered

    • A comparison of the account holder's identity to the government lists of known or suspected terrorists

  4. Timely Escalation and Resolution

    • Timely reports

    • Appropriate reviews of the report

    • Identify the outcome / resolution of matters

  5. Explicit Management Support

    • Senior management should set the tone

    • Their support clearly visible to all employees

  6. Sufficient Training and Education

    • Integral to the whole programme

    • Courses on how to recognise suspicious activity and what to do next

  7. Regular Review of the Program

    • To make sure it is working as designed

    • Accompanied by a formal assessment / report

NotesQuizPaper exam