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How to establish an anti money laundering policy

If your business comes under the government’s Money Laundering Regulations 2007, it needs to have an anti-money laundering policy in place. If you need help with your policy, whether you want to write a new one or check an existing document, there are certain details you need to think about.

Money laundering is the process of hiding the origins of illegally obtained money, potentially by using it as part of a legitimate transaction. If a business is found to be laundering money, the consequences can be severe.

For in-depth advice from an anti-money laundering expert, catered to your specific industry, contact First4lawyers. We can even arrange training or help to set up online solutions.

What to write in an anti-money laundering policy

An anti-money laundering policy must make clear what is expected of staff, who the policy covers, and actions that need to be carried out. It must ensure everyone who reads it understands what money laundering is so that they can act against it.

  1. Introduction

    This should explain if the company is included under The Money Laundering Regulations 2007 and explain what the document is.

  2. Policy scope

    This should cover who must follow the policy and regulations.

  3. What is money laundering?

    This section should explain what money laundering is, explaining in plain English combined with official definitions. It should also explain why it is illegal, and why employees must be diligent in protecting against it.

    Our guide on how to identify and report money laundering can help to break this down.

  4. Requirements of the legislation

    This section should summarise what is expected of businesses in an anti-money laundering policy, such as appointing a reporting officer, and so on.

  5. Money laundering reporting officer

    As the document should serve as educational and as a place of referral, this section should explain who the businesses’ reporting officer is, how they can be contacted, and who should be contacted if the officer is absent or unreachable. This must always be up to date.

  6. Customer due diligence

    A company must ensure a customer is who they say they are before a transaction even takes place. This can be done by checking legal photographic identification, statements, and places of residence.

    This section should cover why this due diligence is required, and how to carry it out.

  7. How to report suspected money laundering

    This will be detailed. It should include how to report anything suspicious to the reporting officer, and how to write up a full case of the suspicious activity.

    The guide should be written clearly in step-by-step directions, telling the reader how to safely and securely write the report.

    It is also important to make clear that the employee should not investigate the case further as this could be dangerous and implicate them in the scheme.

  8. The actions of the reporting officer

    Similarly to the above, this should explain step-by-step the actions the company’s reporting officer will take before deciding whether to push the case onto higher regulating bodies.

  9. Training and further steps

    The document should finish by explaining any training that employees should expect to take, the positions that require training, and how they will be notified about it.

    Before you write your anti-money laundering policy, take a look at our template, which includes samples of phrasing and the step-by-step instructions highlighted above.

  10. (CTA)

    Does your businesses fall under The Money Laundering Regulations 2007?

    All sorts of businesses and industries must legally carry out anti-money laundering policies. These include financial and credit businesses (such as cheque cashers), legal professionals, estate agencies, casinos, and accountants, plus other similar organisations.

    Smaller businesses that aren’t covered by larger regulatory bodies in these industries must be registered with HMRC, or risk a fine. On top of registering, it’s worth having an official anti-money laundering policy in place, and having all members of staff understand and follow out the requirements as part of their role.

    Want to learn more about money laundering?

    Professional training is essential for any business that needs to establish an anti-money laundering policy. Contact First4lawyers to explain your business’s requirements, and we’ll put you in touch with the best educators for your industry.