Does your firm’s AML policy put your firm at risk? How often does your firm update their AML Policy? Does your firm’s MLRO have the resources to consider what updates should be included to tailor the firm’s policy?
Regulation 19 of the Money Laundering Regulations 2017 requires that you regularly review your PCPs.
What does ‘regularly’ mean? As a subjective concept, this may well mean different things to different practices, depending on the size and nature, the risk profile and so on. Many experts suggest that an annual review would be stretching the limits of ‘regular. This does not mean that you are expected to update your policy monthly. You may wish to consider updating the policy quarterly. You may wish to bring this forward due to any of the following:
With Lexsure’s AML Policy Update Service you can receive updates about the latest and relevant paragraphs for you to consider including in your AML policy. Typically, we send out a monthly notification listing the five new paragraphs drafted in the previous month.
Updating your AML policy is particularly important given the constantly moving landscape of AML risk management.
This service is only applicable to SRA regulated law firms in England and Wales