Monitoring & review

Monitoring & review

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended, require firms to establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering, terrorist financing and proliferation financing identified in their firm-wide risk assessment. In order to assess effectiveness, some form of monitoring and review must take place.

The policies, controls and procedures must:

•
be regularly reviewed and updated
•
include the monitoring and management of compliance with, and the internal communication of, such policies, controls and procedures

This subtopic provides guidance and tools for organisations to monitor and review the effectiveness of their anti-money laundering (AML), counter-terrorist financing (CTF) and counter-proliferation financing policies, controls and procedures they have established. It reflects the requirements of the MLR 2017, as amended.

See Practice Note: How to monitor and review your AML, CTF and counter-proliferation financing controls—law firms.

File reviews

A system of random audit and file reviews can, among

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