Documentation
The first obligation placed on supervised entities is to have a risk assessment. Then they must “establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering and terrorist financing…”
High Risk Third Countries
High Risk Third Countries can be a confusing area, and exists alongside, not instead of Firm’s own risk assessments.
High-risk and other monitored jurisdictions
In August, HMRC reminded supervised entities that Turkey and Jamaica had been removed from the grey list in June. However, they neglected to mention that Monaco and Venezuela had been added—or “recognised” in the wording of FATF.
AML 4 MSB 11. More SARS
As a general rule -
Money Service Businesses are viewed as high risk. Money Service Businesses do not do enough SAR. When in doubt - report.
AML 4 MSB 10. Suspicious Activity
Anyone in the business who feels something is off should report that to the Nominated Officer. I firmly recommend that these internal reports should NOT be called SAR. (I’ll explain later). Staff should be encouraged to report whenever they feel the slightest bit suspicious.
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Questions? Drop us a line. If we can help, we will.