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Anti Money Laundering Procedures Manual (online)

Anti-money laundering procedures manual

Price: £125+VAT

10% discount for SWAT UK Full Members

Ensure your firm remains up to date and compliant with the Money Laundering Regulations with the help of SWAT UK’s Anti Money Laundering Procedures Manual. 

Product Information

The Anti Money Laundering Procedures Manual is filled with must-have templates, anti money laundering guidance and frequently-asked-questions to help you implement the required procedures quickly and easily. 

The Anti Money Laundering Procedures Manual is a 12 month subscription service. The content of the manual is contained on a single website, allowing you to access the manual anywhere in the world, from wherever you have access to the internet.

Plus, your subscription provides firm-wide access meaning everyone in your firm can access the site.

Content

The manual provides you with guidance, templates and checklists covering the following areas:

  • Recognising money laundering
  • The Proceeds of Crime Act 2002 (as amended in December 2007)
  • The Terrorism Act 2000 (as amended in December 2007)
  • Other anti-terrorist financing legislation
  • The Money Laundering Regulations 2007
  • Detailed guidance on customer due diligence procedures, including beneficial ownership
  • Guidance on risk assessment and management and on compliance management
  • The role of the MLRO
  • Internal and external reporting procedures
  • Anti money laundering training requirements
  • Example policies and procedures, checklists and other specimen forms and letters

Latest Updates

The Anti Money Laundering Procedures Manual was last updated in November 2016.

Please click here to see all the latest updates

Draft 2017 Regulations published at last!

On 15th March 2017 the government published draft money laundering regulations and a further consultation. Copies of these are available from https://www.gov.uk/government/consultations/money-laundering-regulations-2017. The new regulations will be known as the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. This follows the consultation in September 2016 on the implementation of the 4th Money Laundering Directive (4MLD) and the Fund Transfer Regulation (FTR).

The new consultation summarises the responses to the September consultation and explains the government’s policy decisions. The purpose of this consultation is therefore primarily about whether the draft regulations deliver the government’s stated policy aims; although there are some further policy questions posed in the document.

The closing date for comments to be submitted is 12 April 2017. This is quite a short turnaround; however, the new requirements must come into effect by 26 June 2017 in order to comply with 4MLD and FTR.

Key points to note

Some key points to note from the proposed draft regulations are summarised below. 

  • The threshold for registering as a High Value dealer will be reduced from €15,000 to €10,000 otherwise the threshold for one-off transactions remains at €15,000.
  • Formation of a company is to be treated as a business relationship whether or not the formation is the only transaction being carried out for that customer. This will mean that CDD procedures are required rather than applying the exemption for a one-off transaction.
  • The prescriptive list of occasions when simplified due diligence (SDD) can be applied has been removed and replaced by a non-exhaustive list which is more in line with a risk based approach.
  • A similar approach has been taken for when Enhanced Due Diligence measures are required and includes a list of situations where enhanced due diligence as a result of higher risk assessment will be required.
  • Whilst 4MLD effectively brings the entire UK gambling industry into scope the government is taking the option in the Directive for the exemption of all gambling service providers from the requirements of the directive, except remote and non-remote casinos.
  • The government will allow all the exemptions in 4MLD that allow the application of SDD in respect of electronic money products where the risk is low.
  • Letting agents will be retained within the scope of the new regulations where they carry out estate agency work. However, the application of the Money Laundering Regulations will not be extended to include lettings activity.
  • The Regulations clarify that for the purposes of those regulations, an estate agent is to be considered as entering into a business relationship with a purchaser as well with as a seller. This means that estate agency businesses must apply CDD to both contracting parties in a transaction.
  • The risks posed by PEPs, their family members and their known close associates should be assessed on a case-by-case basis and the extent enhanced due diligence (EDD) measures tailored accordingly rather than applying a uniform approach. The definition of a PEP now includes all that meet the criteria not just those in states and institutions outside of the UK.
  • A register of beneficial ownership information for express trusts with tax consequences is planned for summer 2017. This will be administered by HMRC. Any decision about extension of the existing PSC (persons with significant control) regime for companies has been deferred and the consultation invites comments on what other types of entity should be included.
  • Companies and trusts will be required to provide beneficial ownership information to those within the regulated sector within two days of being asked and also to provide details of any changes within two days.
  • The regime for allowing those within the regulated sector to place reliance on checks performed by others within the regulated sector will now apply to all within the regulated sector rather than those regulated by certain supervisory bodies.
  • Persons engaging in financial activity on an occasional or very limited basis with turnover under £100k are outside the scope of the Directive, this was previously set at £64k. However, it should be noted that some specific sectors are excluded from this exemption.
  • The UK National Risk Assessment of Money Laundering and Terrorist Financing published in 2015 must be updated by 26 June 2018. Supervisory bodies must then build the results of this into a Risk Assessment of their area of supervision the results of which should be fed to those they supervise who must then build that into their own individual risk assessment.

We will not be updating the SWAT UK AML systems and training courses until the Regulations are finalised so watch this space for further developments.


*Price excludes VAT and is valid until 31 December 2017. Price is based on a 12 month subscription and is payable in one annual fee. You will need to renew your subscription each year in order to retain access to the manual. 

Please note - we will need to process your order before you can access this manual online, which may take up to 48 hours. As soon as your order has been processed, we will send you an email notification, giving you instructions on how to access the manual online. If you haven't received this within 48 hours of your order, please call us on 0845 450 5555.

Please note - the computer monitor pictured is not included. This is for visual purposes only.