RISK.PO.SRA.002 Anti-money laundering policy v16

This policy sets out the firm’s approach to anti-money laundering and contains sections on the following;

  • Regulatory and legislative obligations
  • What is money laundering?
  • What is terrorist financing
  • Offences and defences under POCA 2002
  • Offences under MLR 2017
  • Offences under TA 2000
  • Penalties
  • What is covered by the regulations
  • Roles and responsibilities
  • Firmwide risk assessment
  • Client due diligence
  • Sources of funds and source of wealth
  • Beneficial ownership
  • Politically exposed persons
  • Ongoing monitoring
  • Cash payments
  • Disclosures
  • Suspicious activity reports – reporting procedure
  • Sanctions checking
  • Record keeping
  • Training

The document refers to, and complies with the following Regulation or Standards;

  •  SRA Standards and Regulations
  • CLC Code of Conduct
  • Lexcel V6.1 Standard
  • CQS standard
  • MLR 2017 (as amended by 5MLD effective 10 January 2020)
  • POCA 2002
  • TA 2000

The document/policy is also available as part of CQS core documents bundle and the Anti-money laundering core documents bundle The document costs £195 +VAT and is available in Word.

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