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
1. Overview
2. Money Laundering Regulations 2017
3. 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
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
9. Ongoing monitoring
9.1 What is ongoing monitoring?
9.2 Sources of funds (e.g., property purchases etc.)
9.3 Sources of Wealth (SoW)
9.4 2023 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
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 High-risk Third Countries
11.6 Submitting Better Quality Suspicious Activity Reports (SARs)
11.7 Registered Charities
12. Cryptocurrencies and Other New Technologies
13. Cash receipts
14. Financial Sanctions
13.1 Sanctions Basics
13.2 Treasury Sanctions List
15. New Products, Business Practices or Technology
16. Monitoring & Review
17. Acknowledgement Provision
