Tag: CQS AML Policy
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SRA AML Audit Results in £23k fine
A CQS accredited firm operating from two small offices in the south west has been hit with a £23,000 fine for failing to comply with AML regulations. Lexsure has announced a tenfold increase in weekly enquiries concerning their AML audit solutions since this fine was announced. CQS firm Batchelor Sharp was issued with the sanction…
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How do the SRA decide which CQS firms to inspect?
The SRA adopt a risk-based approach to AML supervision. The SRA visits a greater number of firms classified as high risk, while also conducting visits to low and medium-risk firms. It is important to note that a visit does not automatically imply that your firm is deemed high risk for potential money laundering activities. To…
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Sanctions risk assessment: What is involved?
Is is considered best practice to align a firm-wide sanctions risk assessment with the requirements of the MLR2017. These regulations outline several risk factors that should be taken into account. They include: The risk assessment must align with the scale and scope of your practice, considering any factors that may influence risk, such as: Whatever…
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Sanctions regime – Why firm-wide risk assessments are a must
The firm-wide risk assessment serves the crucial purpose of identifying potential vulnerabilities to breaches of the regime and exploring ways to mitigate these risks. Although the sanctions regime is characterised by strict liability rather than risk-based, implementing this framework aids in the identification of emerging risks and facilitates the adoption of preventative measures. The Office…
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Updating your CQS AML Policy
As a lawyer you could be forgiven for thinking that money laundering regulations are evolving every day. It is crucial for CQS accredited firms to diligently uphold their AML Policies controls and Procedures. This involves ensuring that all documentation is kept up to date in line with regulatory changes to optimise full compliance. Everyone in…