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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.
