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    Mlro Responsibilities Checklist 20Q1 PDF

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    Mlro Responsibilities Checklist 20Q1 PDF

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    266 views1 page

    Mlro Responsibilities Checklist 20Q1 PDF

    Uploaded by

    Elena Diana

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    © All Rights Reserved
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    of 1

    MONEY-LAUNDERING REPORTING OFFICER CHECKLIST

    Our MLRO checklist will help you to benchmark your existing anti money-laundering procedures and
    processes, conduct a self-assessment on your MLRO role or create a specification for a new role.
     Act as an Approved Person undertaking Controlled Function SMF17 for the prevention of money
    laundering.
     Develop and maintain the firm’s anti-money laundering and counter-terrorist financing policy in line with
    evolving statutory and regulatory obligations.
     Support and co-ordinate management focus on the money laundering risk in individual business areas.
     Assist management in developing and maintaining an effective anti-money laundering and counter-
    terrorist financing compliance culture.
     Ensure that the firm’s risk management policies, risk assessment profile and their application are
    adequately documented.
     In consultation with management, create and maintain the money laundering risk-based approach and the
    risk assessment of the firm’s customers, products and services.
     Establish and maintain appropriate risk-based monitoring processes that are proportionate to the scale,
    nature and complexity of the firm’s operations.
     Develop internal procedures in line with the requirements of the legislation and the relevant industry
    guidance.
     Document the firm’s risk-based strategies and the basis for the risk-assessment and monitoring process.
     Ensure all internal suspicious activity reports received are investigated without delay.
     Ensure that a SAR is submitted to the relevant law enforcement agency in respect of all suspicions that
    have substance.
     Ensure that all staff are aware of their personal obligations and the firm’s policies and procedures and that
    the basis for the firm’s risk-based approach is understood and applied.
     Ensure that staff comply with the stated policy and therefore monitoring operations and development of
    the policy to this end.
     Ensure that all relevant staff are adequately trained in money laundering and terrorist finance prevention,
    that the standards and scope of the training is appropriate and that appropriate training records are kept.
     Regularly review the effectiveness of money laundering compliance policies and procedures to prevent
    money laundering and counter the financing of terrorism.
     Provide management information as necessary including an Annual Report each year for the Bank’s Board
    and senior management on the firm’s compliance with its obligations.
     Make recommendations for action to remedy any deficiencies in policies, procedures, systems or controls
    and follow up on those recommendations.
     Represent the firm to all external agencies, e.g. regulators or law enforcement agencies, and in any other
    third party enquiries in relation to money laundering prevention, investigation or compliance.
     Remain aware of any relevant sanctions, prohibition or advisory notices. Also, if necessary, advise
    management and relevant staff of the names of any individuals and institutions on the sanctions list.
     Promptly respond to any reasonable request for information from the regulator and/or law enforcement
    agencies.

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