FCRM provides anti money-laundering ("AML") services to clients, assisting them to manage and respond to requirements of the UK's AML and Financial Sanctions regime.

For senior management in firms regulated by the Financial Services Authority ('FSA'), HM Revenue & Customs, the Office of Fair Trading, or other UK supervisory body, key risks to manage, include:

• Targeting AML systems and control to address risks relevant to the business.
• Maintaining appropriate client acceptance procedures, to mitigate money laundering risk (including due diligence for standard and higher risk customers/counterparties).
• Providing an internal reporting process to capture money laundering suspicions.
• Appointing a Nominated Officer and/or Money Laundering Reporting Officer ('MLRO').
• AML training for relevant employees who deliver (or supervise) regulated business.
• Complying with systems and control requirements of the Money Laundering Regulations.
• Oversight of regulated activity outsourced to third party service providers.
• Validating application of AML systems and control in practice.
• Complying with regulatory requirements (e.g. the FSA Handbook).

FCRM can assess/benchmark client AML arrangements against UK good practice, as set out in guidance produced by the Joint Money Laundering Steering Group ('JMLSG Guidance'), or by reference to a client's local or Group AML procedure.

Financial sanctions

Financial sanctions are used by national governments as an enforcement tool when diplomacy has failed. Measures imposed can vary from the comprehensive – prohibiting the transfer of funds to a sanctioned country and freezing the assets of a government, the corporate entities and residents of the target country, to more targeted freezing of assets owned (or for the use of) individuals or entities.

A target match is where an account held in a firm is that of a target of the financial sanctions regime. Positive target matches must be reported to the HM Treasury Sanctions Unit ('HMTSU'), and where an account holder is subject of a financial sanction, the account must usually be frozen and details reported to HMTSU.

"To move money obtained illegally through banks and other businesses, to make it appear to have been obtained legally."

UK financial services firms regulated by the FSA are required to maintain effective systems and controls to mitigate money laundering risk; and they must also comply with the requirements of:

• SYSC 3.2.6R - Systems and controls in relation to compliance, financial crime and money laundering.
• SYSC 6.3 - Financial Crime.
• The Money Laundering Regulations 2007.
• The Proceeds of Crime Act 2002.
• The Terrorism Act 2000 (as amended by the Anti-Terrorism Crime and Security Act 2001).

Offences committed can lead to fines and/or imprisonment for firms, managers or employees who fail to manage money laundering risk.

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To request further information about FCRM´s AML services click-here, or to launch your local email application click here.