On the 26th June 2017, under the Fourth Money Laundering Directive (4MLD), the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 came in to force. Changes were also made to the Proceeds of Crime Act (POCA).
Under the MLR2017 and legislation it is a requirement by law to have a nominated money laundering reporting officer (MLRO) in the regulated sector. MLRO’s and their deputies will need to ensure that all policies, procedures and internal controls have been updated to incorporate the changes and training has been provided for the staff.
The SRA have already conducted their first thematic review under the new regulations. What were their findings? How much have you put in place under the 2017 regulations?
The course will cover:
- The appointment of the MLRO
- Job description – what does the role cover
- The Money Laundering Regulations 2017:
- Risk assessment requirements and the role of the MLCO
- Changes made to due diligence
- Capturing of client information
- Identifying the source of funds and wealth
- The extended definition of a PEP
- Beneficial owners
- Record keeping
- MLR2017 and Data Protection
- Training – who, what, when and how
- Reporting to the NCA – what to report and how to complete a SAR
- Penalties for getting it wrong
- Template documents – what records should you be keeping
- The future – 5MLD and 6MLD