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Chapter 23 4
Accountant’s responsibilities
Money Laundering Regulations impose certain obligations on financial services
businesses, which are designed to assist in detecting money laundering and
preventing the financial services organisations being used for money laundering
purposes.
At a minimum, an anti-money laundering program should incorporate:
Money laundering and terrorist financing risk assessment.
Implementation of systems, policies, controls and procedures that effectively
manage the risk that the firm is exposed to in relation to money laundering
activities and ensure compliance with the legislation, including:
– Appointment of a Money Laundering Reporting Officer (MLRO).
– Establishing internal reporting procedures to the MLRO.
– Procedures for the reporting of suspicious transactions to the Financial
Intelligence Unit (FIU).
– Communication and training of all staff in the main requirements of the
legislation.
– Independent audit function to assess adequacy and effectiveness of the
firm’s procedures.
Compliance with customer due diligence, enhanced due diligence and simplified
due diligence requirements.
Enhanced record keeping and data protection systems, policies and
procedures.
Illustrations and further practice
More details of these requirements are given in Chapter 2
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