Independent audit

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The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 introduced a requirement for certain organisations to establish an independent audit function to audit their compliance with the MLR 2017.

Practice Note: Money Laundering Regulations 2017—independent audit function considers the requirement to establish an independent audit function, and sets out the key responsibilities of and best practices for the function and the differences between independent audit and your money laundering, terrorist financing and proliferation financing risk assessment. It reflects the requirements of the MLR 2017, as amended, and provides guidance which is of general application. You should check whether the MLR 2017 contains additional or varied requirements for your sector and whether your regulatory body has any additional, sector specific requirements.

The requirement to establish an independent

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The European Commission has launched a consultation on a draft Implementing Regulation establishing detailed arrangements for evaluations of general-purpose artificial intelligence models and for enforcement proceedings under Regulation (EU) 2024/1689 (EU AI Act). The Regulation defines the technical and procedural conditions under which the Commission may request and obtain access to models, including APIs, source code, model weights and infrastructure, and requires providers to grant timely and effective access while allowing safeguards to protect the integrity and confidentiality of evaluations. It sets criteria for the appointment and independence of external experts and establishes open selection procedures. The draft also lays down rules governing the opening, conduct and closure of proceedings that may lead to fines, including interim measures in urgent cases, the right of providers to submit written observations on preliminary findings, and structured access to the Commission’s file subject to the protection of business secrets and other confidential information. The consultation closes on 9 April 2026.

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This week's edition of Risk & Compliance weekly highlights includes updates to OFSI’s enforcement guidance, an analysis on the impact of lifting of UK sanctions on a British accountant, the UK government’s new cross‑government sanctions enforcement framework, and new DBT and FCDO guidance documents under the UK’s Belarus sanctions regime. We also cover the Home Office’s 2026–29 Fraud Strategy, a call for evidence on economic crime information‑sharing, and the European Commission’s revised code of practice for AI‑generated content marking under the EU AI Act.

DBT updates guidance on countering Russian sanctions evasion

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