What you get
Two documents, written around your answers, in Word so you can edit them. Order one or both.
AML policy
Your firm's written policies, controls and procedures for preventing money laundering and terrorist financing. It is personalised to your firm from the answers you give us.
Firm-wide risk assessment
A written assessment of the risks your own firm faces. It is based on what you tell us about your sector, your clients, the services you provide and how you deliver them.
Editable Word files
Both documents arrive as Word files. They are yours to edit, adopt and keep up to date as your firm changes.
A guidance note on next steps
A short note that explains what the documents cover, what they do not, and what to put in place next.
What the pack does not cover
This is a stop-gap. It is designed to be in place until you have something more comprehensive. It does not include:
- Client due diligence files. We do not carry out or fix due diligence on your clients.
- Staff training. There is no AML training for your team.
- Replying to your supervisor. We do not respond to a fine, findings or an appeal for you.
- Audit and ongoing updates. There is no independent audit, and we do not keep the documents up to date after delivery.
Who writes it
The documents are written by AML specialists, built on the Money Laundering Regulations 2017 and the guidance for your sector, and reviewed by a person before they are sent.
Inside the AML policy
- Roles and responsibilities, including your MLRO
- Your risk-based approach and client risk assessment
- Customer due diligence, simplified and enhanced due diligence
- Politically exposed persons and ongoing monitoring
- Reliance on others and introduced clients
- Financial sanctions screening
- Reporting suspicious activity, and tipping off
- Cash and client money
- Record keeping, training and independent audit
- New services and technology, and proliferation financing
- Monitoring compliance and review
- Appendices: warning signs for your sector, and an internal report form
Inside the firm-wide risk assessment
- Your firm's profile: services, clients, locations and how clients are taken on
- The method and the rating scale
- Nine risk areas, each with a rating before controls, the controls in place, and a rating after them: customers, services, countries, delivery channels, transactions, staff, financial sanctions, proliferation financing and the risks specific to your sector
- A summary table and an overall rating
- An action plan with owners and deadlines
- When the assessment must be reviewed, and a sign-off page
How your documents are reviewed
A specialist reads your answers, sets the risk ratings from the facts you gave, takes out any control your firm does not have, and checks the documents against the law in force on the day they are sent.