Chapter 27 Flashcards
How should sole practitioners implement AML requirements?
A sole practitioner doesn’t need to:
• Appoint a board member to be responsible for compliance
- Appoint a nominated officer as the sole practitioner will be responsible for submitting external reports to the NCA
- Establish an independent audit function for AML policies, controls and procedures
What is a PEP?
an individual who is entrusted with prominent public functions, other than as a middle-ranking or junior official
What are the 2 AML roles?
One Primarily responsible for receiving internal and making external SARs
One responsible for ensuring the business’s compliance with the AML provisions
These can be combined
What do the AML roles require?
Requires the individuals to have:
• an understanding of the business, service lines and its client
• Sufficient seniority to direct the activities of all members of staff
• The authority to ensure the business’ compliance with the regime
• The time, capacity and resources to fulfil the role
What must the nominated partner (who is involved in receiving internal and making external SARs) have?
- Sufficient seniority
- Authority to make external reports to NCA
- The time, capacity and resources to review internal SARs and make external SARs in a timely manner
How long does a nominated officer have to let the AML supervisor authority of the identity of individuals
14 days
What is the role of the MLRO?
Traditionally included responsibility for internal controls and risk management around MLTF in accordance with sectoral guidance
What topics form part of the MLFT framework?
- Risk based approach
- CDD
- Record keeping
- Internal control
- ongoing monitoring
- Reporting procedures
- Compliance management
- Communication
What should my written policies and procedures document cover?
Main errors required are: • Risk management practices • Internal controls • CDD • Reliance and record keeping • The monitoring and management of compliance with controls & procedures
True or false
Businesses with overseas subsidiaries or branches must establish group wide policies and procedures equivalent to those in the UK
True
What is customer due diligence?
The process by which the identity of a client is established and verifies, for both new and existing clients
What is occasional transaction?
A transaction which occurs outside of a business relationship and has a value of more than €15,000
A business’s AML systems and control use meet which requirements?
The requirements set out in the 2017 regulations
How long must CDD records be kept?
5 years after the business relationship ends
A disengagement letter could provide documentary evidence that a business relationship has terminated
True or false
AML training should be tailored to suit the particular role of the individual
True
