AML policies, controls, procedures and MLRO workflows
Guidance for internal controls, nominated officer workflows, SAR escalation, and staff responsibilities.
What policies, controls and procedures cover
Regulation 19 of MLR 2017 requires written policies, controls and procedures proportionate to the firm's size and risk. Regulation 21 requires the nominated officer and, where appropriate, a compliance officer at management level. Together these make the difference between a firm that intends to comply and one that can demonstrate how.
Where the SAR duty sits
The suspicious activity reporting obligation comes from POCA 2002 rather than MLR 2017, and it attaches to individuals as well as firms. Staff escalate internally to the MLRO; the MLRO decides whether to report to the NCA. Both the escalation and the decision need to be recorded, including decisions not to report.
Where to start
If you are writing or refreshing a policy, the compliance core material covers what Regulation 19 expects. If your concern is the reporting pipeline, start with the MLRO and SAR workflow, which covers escalation, decision-making, and the tipping-off constraint.
AML Compliance Core
Core AML compliance concepts, programmes, regulations, reforms, and control frameworks.
BrowseMLRO & SAR Reporting
Internal suspicious activity escalation, MLRO decisions, SAR records, and DAML considerations.
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