AML Responsibility and Oversight Flashcards
What type of penalties can be levied if a business fails to meet its obligations under the Money Laundering and Terrorist Financing and Transfer of Funds Regulations 2017?
Civil penalties and criminal sanctions
According to AMLGAS, the person appointed as a business’s ‘nominated officer’ must have what?
Sufficient seniority to enforce decisions
Time and capacity to review internal and make external suspicious activity reports
Which one person is responsible for both a business’s compliance with AML provisions and its reporting responsibilities?
MRLO
How often does the CIOT/ATT recommend that a business should reviews its AML policies and procedures in its AML supervision FAQs?
Annually
You are the money laundering reporting office at your firm and have been signed off due to illness for four weeks, who can make external SARs during your period of absence?
An internal deputy or internal delegate
What are the main areas where policies, controls and procedures are required by a tax adviser according to CIOT/ATT AML supervision FAQs?
CDD
Internal controls
Reliance and record keeping
What is a ‘relevant employee’?
An employee with work relevant to the compliance with regulations
An employee who is capable of contributing to the prevention or detection of money laundering and terrorist financing in relation to the business
An employee who contributes to the identification and mitigation of the risks of money laundering and terrorist financing to which the business is subject
What requirement should a sole trader implement for their AML responsibilities?
Establish a system for performing CDD
What is a sole trader not expected to do to comply with AML?
Appoint a nominated officer
Establish an independent audit function
Appoint a board member
Where the money laundering reporting officer is split between two individuals, how should duties be assigned?
The business may use its discretion as to how to assign the duties
How is an ‘occasional transaction’ defined in CCAB’s AMLGAS guidance?
A transaction which occurs outside a business relationship and has a value of more than 15,000 euro
In what circumstances is a member required to consider the implications of the Criminal Finances Act 2017 and the Corporate offences of failure to prevent the criminal facilitation of tax evasion?
When operating through a partnership or through incorporated bodies
