With the continuing attention dedicated to large firms’ AML compliance (including regulatory action) by the SRA, itself under supervision by The Office for Professional Body Anti-Money Laundering Supervision (OPBAS), we are seeing a focus on a number of areas.
One of these is independent audit under Regulation 21 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. We have audited many firms, including US and UK based international firms and their overseas offices, and have experience of doing this remotely to address current restrictions.
Other areas of AML compliance where we have been assisting clients remotely include training, which can be provided even to staff who are furloughed. Areas of training to consider include focused sessions for the firm’s AML compliance and client and matter inception team, others who may need to take over the duties of the Money Laundering Reporting Officers (MLROs) or their deputies in times of absences or illness, and new Money Laundering Compliance Officers and MLROs.
The Legal Sector Affinity Group (LSAG) has published an Advisory Note: COVID-19 –and preventing Money Laundering/Terrorist Financing in Legal Practices, and the Financial Action Task Force (FATF) has published COVID-19-related Money Laundering and Terrorist Financing Risks and Policy Responses. A European Commission press release on 7 May 2020 announced an Action Plan,
including a new list of third countries with strategic deficiencies in their anti-money laundering and counter-terrorist financing frameworks; six countries have been removed and 12 added. The list should be confirmed in the next month.
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