ACCA AAA INT Syllabus A. Regulatory Environment - Anti-Money Laundering Programme - Notes 10 / 11
The MLRO is responsible for setting up the anti-money laundering programme
The following is required
Dedicated Resources
An MLRO in place
The MLRO has appropriate knowledge, experience and responsibility
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
Comprehensive Coverage
All aspects of a company's business, particularly those that
have contact with customers should be coveredA comparison of the account holder's identity to the government lists of known or suspected terrorists
Timely Escalation and Resolution
Timely reports
Appropriate reviews of the report
Identify the outcome / resolution of matters
Explicit Management Support
Senior management should set the tone
Their support clearly visible to all employees
Sufficient Training and Education
Integral to the whole programme
Courses on how to recognise suspicious activity and what to do next
Regular Review of the Program
To make sure it is working as designed
Accompanied by a formal assessment / report