Themed Examination Programme 2019 – The Role of the MLRO (it's out)
24/02/2020
Themed Examination Programme 2019 – The Role of the MLRO (it's out)
In November 2018, the JFSC set out in high-level terms its planned thematic examination programme to be undertaken in 2019, within which the theme of the role of the Money Laundering Reporting Officer (MLRO) was identified.
The objective of the thematic examination was to review and assess, where relevant, the following:
- Whether the MLRO had appropriate independence, sufficient seniority and authority in the business;
- The MLRO’s assessment of internal SARs;
- The decision of whether or not to externalise a SAR was always documented appropriately;
- The Relevant Person’s governance, oversight and support of the MLRO; and
- The effectiveness of the Relevant Person’s internal control systems in respect of all the above.
There are 12 key findings
- Reporting Requirements
- Documenting Enquiries and Decisions
- Timeliness of Internal SAR Reporting
- Timeliness of External SAR Reporting
- Oversight by the Board / Management
- Acknowledgement of Internal SARs
- Apportionment and Awareness of Responsibilities
- Procedures
- Training and Awareness
- SAR Register
- Barriers to Reporting
- Independence
Out of the 12, there were two areas which reflected a considerable number of findings across Relevant Persons examined by the SEU and the PSU:
- Procedures; and
- Training and awareness
Please click here to read the report.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.