A policy statement is a document that includes your anti-money laundering policy, controls, and the procedures your business will take to prevent money laundering. This can also help with onboarding new employees to make sure they know the process for identifying and verifying customers. This should detail:
Your anti-money laundering policy and procedures – including naming relevant individuals and their responsibilities.
Your procedures on a risk-based approach for identifying and verifying customers.
Your commitment to training employees so they’re aware of their responsibilities and the need to promptly report suspicious activity to the nominated officer.
A summary of the monitoring controls that are in place.
The UK’s Money Laundering Regulations 2007 highlights that all businesses within the regulated financial services sector are required to appoint a Money Laundering Reporting Officer (MLRO).
The MLRO – sometimes referred to as a ‘nominated officer’ – provides oversight for their firm’s anti-money laundering (AML) systems and acts as a focal point for related inquiries. Not only is having a Money Laundering Reporting Officer a legal requirement, it can also help with:
Having a “nominated officer” for employees to report suspicious activity to.
Identifying the responsibilities of senior managers and providing them with regular information on money laundering risks.
Training relevant employees regularly on their anti-money laundering responsibilities and keep accurate records.
Documenting your anti-money laundering policies and procedures.
It is essential that you keep comprehensive records of all your customer due diligence measures that you carry. Records need to be kept for five years and stored in a secure location. If you have more than one office, annual audits of your additional branches will need to be carried out and recorded. Some of the records you should include:
Your policies, controls, and procedures.