Developing and maintaining a compliant Anti Money Laundering Strategy

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Developing and maintaining a compliant Anti Money Laundering Strategy


The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) and Amendment Regulations 2019 sets out the businesses which are required to comply with the regulations and the actions they must take. Identifying if your business is caught by the regulations is relatively straightforward and will include:

  • Money service businesses not supervised by the Financial Conduct Authority (FCA)
  • High value dealers
  • Trust or company service providers not supervised by the FCA or a professional body
  • Accountancy service providers not supervised by a professional body
  • Estate agency businesses
  • Bill payment service providers not supervised by the FCA
  • Telecommunications, digital and IT payment service providers not supervised by the FCA
  • Art market participants
  • Letting agency businesses

However, it is not so easy to identify what a business must do to comply with the regulations on an ongoing basis as the requirements are set out throughout the regulations. It is therefore necessary to understand and interpret the full regulations to enable your business to comply with the regulations. Unfortunately, it is the application of ALL the requirements where a number of businesses fall short and despite taking steps to comply with some of the regulations, failure to apply all of them, amounts as a breach which exposes the business and its staff to risk.

This article assists businesses and their owners in identifying the action they must take to ensure the business and its staff comply with the regulations.

At AML & Compliance we have developed cost effective, packaged solutions for businesses to fast track compliance and remain compliant. For full information on our services you can contact us on  0203 985 8553 or make an online enquiry

The elements that a business must consider are:

  • Deliver an AML Policy that is documented and sets out the businesses approach to AML.
  • Appoint a Money Laundering Compliance Officer (MLCO) and a Money Laundering Reporting Officer. This can be the same person.
  • Train ALL staff ANNUALLY on AML requirements, the firm’s approach and the action the must take when facing AML related issues.
  • Ensure Client Due Diligence (CDD) is undertaken on all clients (private and commercial). Devise and implement appropriate forms or checklists to ensure those involved in the CDD process are fully aware of what to do and record the action taken.
  • Ensure that Enhanced Due Diligence EDD is applied where appropriate (high risk matters).
  • Ensure CDD is kept up to date for clients, both new and repeat clients.
  • Ensure appropriate measures are in place to identify all clients using appropriate resources.
  • Undertake random AML audits to evidence compliance with the business’s policies and that CDD is being applied at all times.
  • Interview staff as part of understanding AML application (Part of a routine audit requirement).
  • Implement checklists to be completed before opening or closing a file.
  • Set up a process to receive all Suspicious Activity Reports (SAR) from staff and provide access to the MLRO
  • Maintain a central register of money laundering issues and the investigation plus reports made to the NCA, OFSO or HMRC.
  • Notify Companies House of irregularities on the public register and the reality.
  • Review the AML policies annually.
  • Undertake a firm wide risk assessment annually.

If a business fails to implement all of the above it will not be compliant with the AML regulations and therefore be at risk.


Compliance with the AML regulations is not as simple as it may first seem and often expert advise and guidance is essential to ensure your business achieved a compliant status and maintain it. AML & Compliance have developed packaged solutions for businesses enabling our clients to achieve a compliant status and we then work with them on an ongoing basis. This enables the owners and staff to focus on services their clients and running the business knowing that their AML requirements are taken care of.

Our service includes as standard:

  • Drafting bespoke policies
  • Training of Staff
  • Annual Audits  
  • Annual Risk Assessment    
  • Access to a helpline    
  • Implementation of notification forms 
  • Implementation of checklists
  • Implementation and management of registers to record information        
  • Reporting on all activity to evidence compliance     
  • Ongoing updates to policies and new letters to educate and share intelligence