All BCCA members are required to comply with the UK legislation covering anti- money laundering and counter financing of terrorism. This includes the Proceeds of Crime Act 2002, Terrorism Act 2000 and the Money Laundering Regulations 2007.

To comply with the legislation, firms need to ensure that they put policies and procedures in place which include/cover the following:

  • Responsibilities under the legislation. This should include the company, manager and individual employee responsibilities.
  • The Risk of money laundering and terrorist financing faced by the firm and how this is reduced.
  • Frequency of risk assessment.
  • The identity and responsibilities of the Nominated Officer/Money Laundering Reporting Officer.
  • Customer Due Diligence requirements.
  • How you identify and handle Politically Exposed Persons (PEP’s).
  • How you monitor compliance.
  • Transaction monitoring procedures.
  • Recognising suspicious activity.
  • How to make a report to the Nominated Officer or MLRO including obtaining “Consent”.
  • Record keeping.
  • Training
  • Checking Financial Sanctions Lists.

Money Service Businesses (MSB’s) can find more information on what they need to do to comply, by looking at  HMRC’s Money Laundering Guidance for MSB’s.

Firms regulated by the Financial Conduct Authority (FCA), should take a look at the Joint Money Laundering Steering Group (JMLSG) guidance and the FCA’s Financial Crime Guide.

It is important to note that Money Laundering Regulation is changing. On the 26 June 2015, the European Union’s Fourth Anti-Money Laundering Directive came in to force.

European member states have until 26 June 2017 to update their respective money laundering laws and transpose the new requirements into local law by 26 June 2016.

On 21 June 2016, the government published an action plan for anti-money laundering and counter-terrorist finance prevention in the UK. This plan is said to represent the most significant change to the regime in over a decade.

We will be making sure members up to date on these changes via our weekly newsletter Insight and our regular Extra briefings.