Tag Archives: Anti Money Laundering Policies Controls & Procedures Manual

Do We Report Client with Undisclosed Overseas Bank Account?

Question from a firm – I am the MLRO in our firm. I am not sure whether I must or cannot report a situation I have been made aware of. Our client came to Ireland some years ago and for a few months she was unemployed but lived in a hotel. Our Tax Manager asked… Read More


Repeating Money Laundering Checks

Question from a firm – When a client moves address, do you need to redo the Money Laundering (ML) verification checks? Answer – You should obviously update your records and then consider, on a risk sensitive basis, what (if any) evidence you need to support the change (e.g. obtain copy of a utility bill for… Read More


Must AML Training include a Quiz?

Question from a firm – As a follow up to last week’s question about the temporary staff and contractors, that work for us perhaps only for a few weeks or a month or so. We ask them to read our in-house AML Policies Controls & Procedures Manual and view the training webinar including the quiz.… Read More


Who Needs Anti Money Laundering Training

Question from a firm – From time to time we have temporary staff and contractors, perhaps only for a few weeks or a month or so. We ask them to read our in-house AML Policies Controls & Procedures Manual and view the AML training webinar including the quiz. Are we being over-zealous by insisting on… Read More