A step-by-step Anti-Money Laundering breakdown for ICB Practice Licence holders.

Appoint an MLRO

You must appoint an MLRO for your practice unless you are a sole practitioner with no employees, in which case you will be the MLRO by default. 

Understand the MLR

You should ensure you understand what is meant by 'Money Laundering' and the 'Proceeds of Crime'.  You can do this by reading the MLR Pages of the website including the MLR Legislation page and working through the MLR Presentation slides, both available from the right hand menu. You should also conduct any further research you deem necessary, attend local MLR events and feel free to call us on 0845 060 2345 for more guidance.

Understand your Responsibilities

From the above research, you should be clear how the MLR affect you and what your responsibilities are, including what to do when you suspect Money Laundering and how to submit a SAR.

Implement Policies and Procedures

These should cover the following:

a.    Client risk assessment and management
b.    Client due diligence and ongoing monitoring
c.    Record Keeping
d.    Internal Control
e.    Communication/Training for yourself and any staff
f.     Reporting 

If you are unclear about any of the above please refer to the downloadable ICB Targeted Guidance on the MLR Legislation page.

Sign a Policies and Procedures Statement

You can produce your own statement or use the template provided.  Visit the Forms & Checklists page to download the template.

Risk Assess your Clients

Add each client to your secure AML Online record and carry out a risk assessment for each.  AML Online will walk you through all the steps you need to consider in your assessment.

Complete Client Due Diligence

Carry out the requisite due diligence checks for each of your clients, keeping a copy of the documentation you obtained. You can use the Due Diligence form on the Forms & Checklists page as a ready reckoner to remind you of the sort of thing that you might need to consider.  

Do not forget to make a note of what due diligence you completed on the client's entry in your AML Online record.  

Annually Review AML Online

You have an ongoing duty to monitor your clients.  You should revisit your risk assessments for each client and make any updates in AML Online at least annually.

Annually Review AML Policies & Procedures

Make sure you are happy with the processes you have established to comply with the MLR. Visit the Forms & Checklists page for a prompt sheet on what to consider. 


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