CQS (CPMS) Anti-Money Laundering Policy

The recent update to the CQS Core Practice Management Standards (CPMS) requires CQS firms to have a policy in place in relation to anti-money laundering (s5.12).

CQS Policy documents can be time-consuming and difficult to prepare without a Policy Template as a starting point.

The Anti-Money Laundering Policy Template includes reference to:

• Money Laundering Regulations
• Client Due Diligence (CDD)
• Enhanced due diligence: High risk matters and clients
• Reporting suspicious transactions

...as well as other formalities and general obligations as required under 5.12 of the CPMS.

CONTENTS
Change Control
Document Control
Associated Policies
Contents
1. Overview
2. Money Laundering Regulations 2017 (as amended)
3. Training
3.1 AML Training
4. Roles
5. Client Due Diligence (CDD)
6. Client identification
6.1 Identification and verification
6.2 Documents
6.3 Clients who are not physically present
6.4 Reliance on others
6.5 Evidence required
6.6 Lack of evidence of ID
6.7 Digital identity verification and Trust Framework compliance
7. Beneficial owners
7.1 Duty to identify beneficial ownership
7.2 Checking beneficial owners
8. Risk assessment
8.1 What is risk assessment?
8.2 Enhanced due diligence: high risk matters and clients
8.3 Politically Exposed Persons (PEPs)
8.4 Simplified due diligence – low risk clients and matters
8.5 Supply chain risk
9. Ongoing monitoring
9.1 What is ongoing monitoring?
9.2 Sources of funds
9.3 Sources of Wealth (SoW)
9.4 2025 LSAG Guidance + Checklists
10. Reporting suspicious transactions
10.1 Why report?
10.2 Privilege
10.3 Asking the client to clarify
10.4 Tipping off / prejudicing an investigation
10.5 How to report
10.6 Authorised and protected disclosures
10.7 Responding to AML enquiries from the authorities
10.8 5MLD requirements – reporting on a company's beneficial ownership
10.9 Submitting better quality Suspicious Activity Reports (SARs)
11. Detecting money laundering
11.1 Suspicion
11.2 Grounds for suspicion: general
11.3 Grounds for suspicion: property
11.4 Chinese underground banking and funds from China
11.5 Commercial Property and High Street Retail Fronts
11.5.1 Risk Overview
11.5.2 Enhanced Due Diligence
11.5.3 Compliance Controls
11.5.4 Red Flags and Escalation
11.6 High-risk third countries
11.7 Registered charities
12. Cryptocurrencies and other new technologies
13. Cash receipts
14. Financial sanctions
14.1 Sanctions basics
14.2 UK Sanctions List
15. New products, business practices or technology
16. Monitoring & review
17. Data collection accuracy
18. Regulatory transition – supervisory transition & data readiness
19. Acknowledgement provision