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 Anti-Money Laundering Policy

Anti-Money Laundering Policy

1. MONEY LAUNDERING DEFINED

1.1 What is money laundering?

1.2 What is the legal and regulatory framework?

 

2. RESPONSIBILITY and OVERSIGHT

2.1 What are the responsibilities of the business?

2.2 What are the responsibilities of senior management?

2.3 What policies, procedures, and controls are required?

- Risk assessment and management

- Customer due diligence (CDD)

- Reporting

- Record keeping

- Training and awareness

- Employee screening

- Monitoring policies and procedures

 

3. RISK-BASED APPROACH

 3.1 What is the role of the risk-based approach (RBA)?

 3.2 What is the role of senior management?

 3.3 How should the risk analysis be designed?

 3.4 What is the risk profile of the business?

 3.5 How should procedures take account of the RBA?

 3.6 What is client risk?

 3.7 What is service risk?

 3.8 What is the geographic risk?

 3.9 What about other risks?

 3.10 How important is the documentation?

 

4. CUSTOMER DUE DILIGENCE (CDD)

4.1 What is the purpose of CDD?

- Principles of CDD

- Stages of CDD

- Ultimate Beneficial ownership

4.2 When should a CDD be carried out?

- Establishing a business relationship

- Ongoing monitoring

4.3 How should it be applied?

−Applying CDD in a risk-based approach

- Simplified due diligence (SDD)

- Enhanced due diligence (EDD)

- Politically exposed persons (PEPs)

- Financial sanctions

- Reliance on other parties

- Group engagements

- Subcontracting

4.4 Evidence gathering

- Copies

- Use of electronic data

4.5 What happens if CDD can't be applied?

- Cessation of work and suspicious activity reporting (SAR)

 

5. SUSPICIOUS ACTIVITY REPORTING (SAR)

5.1 What must be reported?

- Offenses

 - Internal report to the MLRO (Money Laundering Reporting Officer)

- Contents of a SAR  

- Privileged circumstances

5.2 What is consent?

- Matters requiring consent

- Applying for and receiving consent

- When consent is refused

- Client relationships -

  - - Reporting to other bodies

 

6. RECORD KEEPING

6.1 Training records.

6.2 Third-party arrangements

6.3 Deletion

 

7. TRAINING AND AWARENESS

7.1 What should be included?

7.2 When should training be completed?

 

 

 

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