Money Laundering Regulations 2017 Catching Firms Out
And don’t forget Equality & Diversity…
There are two things that our firms are anxious about at the moment that we thought we’d share with our client base.
The first is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the regulations), which transposed the Fourth EU Money Laundering Directive into UK law which came into force on the 26th of June 2017.
This new complex regulation seemed to sneak up on the profession and pounce with very little warning, and many firms had no idea it was coming in, and very little idea what to do differently when it did.
One of the main provisions of the regulation is a new annual “Money Laundering Risk Assessment” which should be completed by the MLRO and identifies where the firm may need new safeguards, policies or procedures to demonstrate compliance with the Regulation. Ideally this should have been completed by the date the Regulation came into effect…
If anyone reading this is worried about this new Regulation and their firm’s obligations, we can help, just contact us so we can tell you more.
The second thing causing a little anxiety amongst our clients is the SRA Equality & Diversity reporting exercise for 2017. Most authorised signatories and/or COLPS will have received an email from the SRA by now explaining that they can now enter their data on the MySRA portal. That sounds simple enough, but firms also need to remember their requirement to produce their own report which they may or may not need to provide to their clients, depending on Data Protection obligations.
Again, if anyone reading this is worried about SRA diversity data entry and compiling their own report, we can help.
Just email us for more information at firstname.lastname@example.org or, if you already work with one of our consultants, contact them to see how we can help.