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As the UK’s anti-money laundering (AML) supervisors continue to fine across businesses and sectors for poor anti-money laundering procedures, this area of compliance continues to dominate the headlines.
Over the past 12 months, supervisors have imposed a range of sanctions and corrective measures upon firms, including but not limited to, fines for both the businesses and individuals, letters of advice, reprimands, warnings and in some cases, conditions have been placed upon a firm’s authorisation.
At Crowe, our team have been helping clients with their AML audits for over 12 years.
Section 21 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (MLRs 2017) requires a firm to implement internal controls. It requires, where appropriate with regard to the size and nature of its business, firms to establish an independent audit function with the responsibility to:
Firms can undertake their own internal audit, however, the person undertaking the audit should not be involved in writing the firm’s policies or be involved in the day-to-day operation of the AML function, or gathering of customer due diligence etc. The individual should also be familiar with the requirements of the MLRs 2017 and associated legislation, sector guidance and be sufficiently senior within the firm, so that the board will undertake a comprehensive review of the findings and implement recommendations where required/appropriate.
An independent review/GAP analysis of your firms processes and procedures, measured against the legal requirements of MRLs 2017, associated legislation and industry sector guidance. We present our findings with a traffic light system, detailing any deficiencies, if found and providing our recommendations for an AML compliant programme, for the following areas.
Designated Investment Firms (DIFs) that hold client money and/or custody assets in relation to their regulated activities must have a CASS audit. As outlined by the Financial Conduct Authority (FCA), a CASS auditor must prepare a report which gives an opinion on whether the firm:
Other FCA-regulated firms that fall into the CASS regime.
The CASS audit must be delivered within four months of the end of the period. Usually, it is completed at the same time as the financial statements audit, but is a separate exercise, and does not have to be completed by the same auditor.
Our team empower you to deliver your strategic goals by working with you to evaluate:
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We help you to make smart decisions that have lasting value. Working with you, we will help you understand your obligations in order to be compliant with regulatory expectations.