Webinars by Practice Area
Anti-money laundering update 2022
Available from: 10/06/2022
Since 2017 we have had three sets of amendments to the Anti-Money Laundering Regulations of 2017 as well as the new Legal Sector Affinity Group guidance note (all 212 pages of it), which was published early in 2021. As the Covid restrictions have eased, the period of regulatory restraint over the last two years has also faded and the SRA has found new vigour in its approach to compliance.
Firms are now being asked key questions not only about their firm-wide risk assessments, but also about their enquires into source of wealth (as distinct from source of funds), their resourcing of the key roles of MLCO and MLRO, and the prevalence of the RTFM problem. Further, investigations might suggest that more rigorous record-keeping may be in order too.
This webinar will consider the basics of the legislative regime and will explore the approach of the SRA in particular to the blizzard of bureaucracy with which law firms now have to comply.
Topics covered include:
- Key financial crimes, including FinCEN, sanctions list changes and Covid-related cybercrime
- Key PoCA duties and legislative risks
- Overlaps with frauds and scams
- The attitude of NCA to Suspicious Activity Reports
- Key inclusions
- How should they be drafted to maximise their effectiveness?
- Key inclusions of the MLTF Regulations 2017 as amended
- Risk assessments – the 3 layers: Treasury, sectional regulators and professional firms
- Regulators’ investigations – key enquiries and things to focus on
- CDD – the key aspects
- Getting the key documentation
- Vetting the key documentation
- Source of wealth and funds investigations
- Electronic searches – the way forward; new technology and extra assurances
- What to do if you come across a PEP
- Other considerations: Ongoing monitoring; keeping CDD up-to-date and scrutinising transactions throughout (with suggested templates)