For firms regulated by the Financial Services Authority ('FSA'), HM Revenue & Customs, the Office of Fair Trading, or other UK supervisory body, key anti-money laundering ('AML') controls should cover:

• Targeting AML systems and control to address risk relevant to the business
• Maintaining appropriate customer due diligence ('CDD') procedures (including risk-based measures for higher risk customers/counterparties)
• Internal reporting procedures for suspected money laundering
• Appointing a Nominated Officer and/or Money Laundering Reporting Officer ('MLRO')
• AML training for employees who deliver (or supervise) regulated business
• Systems and control requirements of the Money Laundering Regulations 2007
• Oversight of activity outsourced to other parties/service providers
• Assurance testing of AML systems and control arrangements
• Regulatory requirements (e.g. FSA Handbook)
• Acknowledged good practice (e.g. as set out in Joint Money Laundering Steering Group ('JMLSG') Guidance)

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.

R

"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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