Anti-money laundering controls are policies and procedures that you must put in place within your business in order to prevent activities related to money laundering and terrorist financing.
They include assessing the risks of your business being used by criminals to launder money; verifying customers’ identity; monitoring customers’ transactions and reporting suspicious activity to the Serious Organised Crime Agency (SOCA); keeping the right records; and ensuring you have appropriate internal management controls.
You will need to ensure your staff are aware of the Regulations and trained to carry out the necessary anti-money laundering controls.
For existing businesses you need to have these procedures in place on 15 December 2007.
If you are a new business you need to have anti money laundering controls in place and be registered with HMRC before you start trading.
Systems of controls and procedures will defer according to the size and complexity of each business and the risks involved.
HMRC will not dictate what risk-based measures should be in place for your business, it is for you and your senior managers to decide on a reasonable approach which balances the costs to your business and your customers with a realistic assessment of the risks involved.
Businesses should keep relevant documents relating to the risk assessment and management procedures and processes.
Remember you should write down your risk-based policy and procedures and keep these documents up to date. HMRC will ask for details of your policies and procedures.
Your business should establish and maintain appropriate and risk sensitive policies and procedures relating to:
A risk-based approach means directing resources in accordance with priorities so that the greatest risk receives the highest attention.
This has been introduced to:
By adopting a risk based approach businesses are able to ensure that measures to prevent money laundering and terrorist financing are appropriate to the level of risk identified.
Applied appropriately this approach should allow businesses to be more efficient and effective in their use of resources, and minimise burdens on their customers.
Customer due diligence is the term used in the Regulations for the steps that businesses must take to:
You must also conduct ongoing monitoring to identify large, unusual or suspicious transactions.
Full details of anti money laundering controls including more information about a risked based approach and customer due diligence can be found in: