Systems & controls

Is it mandatory to implement systems and controls under the MLR 2017?

If the MLR 2017 apply to your firm, you must:

1. •

   establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering and terrorist financing identified in your firm-wide risk assessment (FWRA)

2. •

   regularly review and update those policies, controls and procedures

3. •

   maintain a written record of:

   1. ◦

      those policies, controls and procedures—see Precedent: Register of AML, CTF and counter-proliferation financing policies, plans and procedures

   2. ◦

      any changes to those policies, controls and procedures

   3. ◦

      the steps taken to communicate those policies, controls and procedures or any changes to them within your business

For guidance on whether the MLR 2017 apply to your firm, see Practice Note: Money