Risk-Based Approach (Policies and Procedures)

Relevant law/regulation: Money Laundering Regulations 20(1)(f), 21

Policies and Procedural Obligations:

  • Firms must establish and maintain adequate and appropriate policies and procedures to forestall and prevent operations relating to money laundering and bribery & corruption
  • Appropriate controls should take account of the risks faced by the firm’s business
  • Introduce appropriate controls to take account of the risks faced by the firm’s business
  • Maintain appropriate control and oversight over outsourced activities

There are separate offences under the ML Regulations, UK Bribery Act and Proceeds of Crimes Act not to establish adequate and appropriate policies and procedures in place to forestall and prevent money laundering and predicate crimes (regardless of whether criminality actually takes place).