Description

AML Policies Controls & Procedures Manual (February 2020) (71 pages) – The June 2019 edition of this Manual has been updated in February 2020 for the following items (even though new AML legislation has not been implemented since then):

• Pronouncement by the FATF arising from their Public Consultation on FATF Draft Guidance on Digital Identity (discussed at the FATF plenary meeting in Paris from 19-21 February 2020)
• The latest developments on the RBO register since June 2019
• Further guidance on carrying out electronic searches and the validity of sourcing electronic data for client identity purposes.

This Manual contains everything you need to successfully implement the requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 which became law on 26 November 2018 and the Register of Beneficial Ownership which came into effect on 22 June 2019.

This Manual comes with a, free of charge, Excel spreadsheet called the ‘AML Control Sheet’ which firms may use to give a ‘helicopter’ view of progress made with keeping client AML data up to date.

The Manual includes eleven Appendices with templates/guidance on how to implement the legislation efficiently.

The Chapter headings in this manual are:

1. AML Procedures
2. The Business Risk Assessment
3. Simplified Due Diligence (SDD)
4. Standard/Normal Due Diligence (NDD)
5. Enhanced Due Diligence (EDD)
6. Third Party Reliance
7. Relevant Third-Party Arrangements
8. Reporting Requirements
9. Exemption from Reporting
10. External Reporting
11. Tipping Off
12. Record Keeping
13. Training
14. AML Compliance Review
15. Penalties & Fines

There are also Eleven appendices as follows:

Appendix I Sample Business Risk Assessment

Appendix II Typical Approach to Verification of Documentation

Appendix III – Beneficial Owner (S.26 – S.30)

Beneficial Ownership Register

Public Registers

Appendix IV – Template Letter re Beneficial Owners

Appendix V – Enforcement

Appendix Vi – The Firm’s Client Risk Assessment And Decision Tree

Appendix VII – Corporate Identity Record Form

Appendix VIII – Personal Identity Record Form

Appendix IX – Example Internal Report of Suspicious Activity Form

Appendix X – Example MLRO Acknowledgement of Internal Report of Suspicious Transaction

Appendix XI – Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies