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Requirements
FSA Evidential Provision 6.2.2 says that firms must provide the following information to staff and make it continuously available:
1. Personal responsibilities under your organisation's arrangements for:
- identifying clients
- using available information to recognise the unexpected and suspicious
- reporting suspicions of money laundering activity
2. Who your organisation’s Money Laundering Officer is and what his or her duties are.
3. The parts of the Law that apply to money laundering, the Money Laundering Regulations 1993 and the FSA Rules.
4. What a breach of the requirements can mean for individuals, your firm and your clients.
Options for meeting these requirements
There is no fixed approach to the means of delivery of information and, consequently, it will depend upon the size and nature of your organisation's operations. The options listed below are worth considering, as they have proved successful in many other organisations.
Booklets or documents summarising the key information
Booklets or documents covering the above information can prove very effective for delivery on induction or on appointment to a new position.
To be truly effective and to motivate the required vigilance and compliance, the content of the booklet needs to relate to the products and services that the member of staff will be involved in. There is really no point, for example, distributing documents addressing retail banking to investment bankers.
Money Laundering Resource provides up-to-date compliance guides for all members of staff in the following sectors:
MLRO reference
Money Laundering Reporting Officers are now required to implement a “risk-based” anti-money laundering regime. In addition to increasing the effectiveness of money laundering prevention measures, this is intended to reduce the regulatory burden on organisations and activities where the money laundering risk is low.
Unfortunately, the onus is placed on the MLRO to work out the details of how their risk-based regime should be implemented. Recognising this problem, the Money Laundering Officer’s Practical Handbook provides a step-by-step action plan for the implementation of your risk-based regime.
>Click here for more on the Money Laundering Officer’s Practical Handbook
To keep informed about money laundering compliance issues as they evolve, Money Laundering Resource recommends the Reporting Officer’s Online Resource. This web-based facility keeps the MLRO fully up-to-date with regulatory requirements, warnings and sanctions, country risks and news.
> Click here for more on the Reporting Officer’s Online Resource
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