Complying with anti-money laundering and counter terrorist financing (AML/CTF) regulation in the EU is one of the most serious challenges faced by a regulated business. Firms are required to establish structures to ensure compliance with AML/CTF regulation in the jurisdiction in which they are based and may also need to establish such structures in other jurisdictions in which they have a presence.
Flawless Money’s regulatory and compliance consultants can use their multi-jurisdiction experience to provide the following services:
- Expert advice on the fourth Money Laundering Directive (4MLD) and the fifth Money Laundering Directive (5MLD), as well as supranational and European guidance;
- Preparing a suite of AML/CTF mandatory documents tailored to individual business requirements, including AML/CTF manuals and accompanying policies and procedures;
- Providing expert advice and opinions on AML/CTF regulatory obligations across a number of jurisdictions;
- Carrying out staged regulatory investigations by ex-FCA staff to prepare for FCA visits and reviews;
- Conducting regular AML audits to test and evaluate compliance programmes and provide recommendations in the case deficiencies are found;
- Developing and implementing a risk-based approach to AML/CTF compliance that is tailored to individual products;
- Advising on the duties and liabilities of the Money Laundering Reporting Officer (MLRO) and the nominated officer;
- Developing policies and procedures for:
- internal and external suspicious activity reporting;
- customer due diligence (CDD), including advising on simplified and enhanced CDD as well as on electronic CDD;
- Advising on and assisting with the implementation of a transaction monitoring system;
- Providing general AML/CTF training for staff and specialized AML/CTF training for the MLRO, the board of directors and the nominated officer; and
- Providing representation when liaising with local FIUs, competent authorities and other law enforcement agencies, both at national and European level.