AML policy documents – Is your business compliant with legal and regulatory requirements? 

When you work in the financial services sector and other related sectors that are at risk of becoming victims of financial crime, ensuring compliance with the Money Laundering Regulations 2017 should be at the top of your agenda—especially given that the National Crime Agency reports that around £10 billion of illegal money is laundered each year! 

With money laundering not only damaging to businesses and their customers, but also the wider economy, firms are required to take preventative measures to block any attempts at money laundering before they have time to come to fruition. As part of these requirements, businesses are required to have an AML policy document.  

These are formal documents created by financial institutions, businesses, or organisations to outline the procedures and protocols they will follow to prevent, detect, and report money laundering activities. Here, we explore the benefits of the documents, and what yours should contain.  

What are the benefits of AML policy documents? 

First and foremostly, AML policy documents are essential for ensuring organisations stay compliant with local and international laws, helping to protect both their reputation and financial health.  

As well as evidence your anti-money laundering policy to regulatory bodies if requested, AML policy documents also help inform your colleagues of the protocols they should be following. Having it in one document that’s easily accessible for all will ensure consistency in the strength of your AML policies and procedures, for better protection against fraudsters.  

What do AML policy documents include? 

Depending on the type of business you work in, and the processes you have in place, AML policy documents can slightly differ. However, generally, an AML policy document will include: 

• Objectives and scope: Defines the purpose of the AML programme, including the organisation’s commitment to preventing money laundering and financing of terrorism. 
• Customer Due Diligence (CDD): Details the procedures for verifying the identity of clients (Know Your Customer – KYC), assessing their risk level, and monitoring transactions for suspicious activity. 
• Risk assessment: Describes the process for identifying and assessing risks related to money laundering across different customer profiles, products, services, and geographies. 
• Transaction monitoring: Outlines the systems and controls in place to detect unusual or suspicious transactions that could be linked to money laundering. 
• Reporting requirements: Specifies how and when suspicious activity should be reported to relevant authorities (e.g., Financial Intelligence Units – FIUs) through Suspicious Activity Reports (SARs). 
• Record-keeping: Details the retention period for financial records, including customer identification, transactions, and reports. 
• Employee training: Establishes guidelines for ongoing employee education on AML laws, red flags, and the organisation’s procedures for compliance. 
• Internal controls and governance: Defines the responsibilities of management and compliance teams in ensuring that AML measures are effectively implemented and maintained. 
• Auditing and testing: Ensures the AML programme is regularly audited and tested to verify its effectiveness and compliance with legal standards.  

Knowing where to start when creating an AML policy document can feel overwhelming, but we’re here to guide you through it. We offer an AML policy document creation service that is tailormade to your organisation, and the sector you operate in. So, you can save time while remaining compliant and keeping your workforce in-the-know about your AML policies and procedures.  

Want to find out more? Get in touch with our friendly team to have a chat about how we can help you to strengthen your AML compliance processes. 

Author

Richard Devine

Solutions Consultant

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