ACCA AAA INT Syllabus A. Regulatory Environment - ACCA factsheet 145 on Money Laundering - Notes 11 / 11
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| The offences | Failing to disclose or report money laundering Tipping off Prejudicing an investigation |
| 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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