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Anti-Money-Laundering and related financial crime issues

Key texts

4th and 5th Money Laundering Directives & Fund Transfer Regulations

UK Money Laundering Regulations

Proceeds of Crime Act 2002

FCA’s FC guidance

FATF Recommendations and assessments



Money Laundering, Terrorist Financing and Sanctions

Proceeds of Crime Act offenses – concealment, arrangements facilitates acquisition, use or retention, acquires or possession, failure to report, tipping off

Overall risk management – identify and assess risks of AML and terrorist finance, MI

Role of MLRO & Board members

UN and OFAC Sanctions

Formal policies and procedures


Client Due Diligence (CDD)

Simplified, client and enhanced due diligence – in theory and practice

Ongoing monitoring of transactions and review of client due diligence

Client, country and activity risk rating

Indicators of terrorist financing

Sanctions screening

Adverse Media Screening

Third party reliance

Expected account activity and monitoring against it


Identification of clients


Beneficial ownership and other controllers

Client types (e.g. individuals, corporates, trusts, etc)

Rules on Wire Transfers – labelling transactions

Source of wealth and specific funds


Danger areas

Distant transactions

Politically exposed persons, family members and close associates

Vulnerability of non-commercial bodies and public contracts

Correspondent banking

Shell banks

Bearer securities


General issues with handling cases

Suspicious activity report (SARs) and suspicious transaction reporting (STR)

Review of ongoing relationship and client’s use of it


General issues


Training obligations

Employee selection issues

Reviews of password access and other IT security issues

Get in touch

Contact Adam by e-mail, phone or post at:

E-Mail: or

Mobile: 07900 248150

The Attic, 117 Priory Road, London NW6 3NN.