Providing in-house guidelines complements money laundering training

Establishing a set of in-house guidelines is an essential part of a firm's money laundering training systems. The Money Laundering Regulations 2007 (the Regulations) state that all Relevant Employees must be aware of the law governing this area, and of the ways in which they should work to operate in compliance with that law.

For many employees, this does not necessarily mean a full legal understanding of the Regulations, the Proceeds of Crime Act 2002 and the Terrorist Act 2000; it means a general understanding of the parts that are applicable to them, and a set of rules, specific to their employer, that should be followed. These rules would be set out in the in-house guidelines, and will, of course, vary from company to company.

By way of example, the Regulations do not give an absolute level at which a cash payment should give rise to a Suspicious Activity Report. The money laundering reporting officer (MLRO) for a financial institution, legal firm or tax advisor should be able to establish a value below which cash payments are not unusual in that business; setting out that value so that every worker within a business knows when to trouble the MLRO, and when not to, will be an important section of the guidelines.

These guidelines should be accessible to all Relevant Employees - and, to follow the spirit of the Regulations, to all partners. This may be as a printed handbook or an electronic document on the company's IT systems, depending on the choices made by the MLRO.

Defining these guidelines, however, can be a complex task, and it may be the MLRO and the organisation will be held liable if workers can show that activities breaching the Regulations were a result of inadequate systems and guidelines.

Money laundering training for Relevant Employees and MLROs
ML Solutions 4U offers accredited training packages for those who must work within money laundering guidelines, and for those who write them. We aim to provide high-quality training designed to provide practical solutions to your business needs, through seminars, in-house training and online instruction.

We can assist companies of all sizes in meeting the onerous duties set out under anti-money laundering legislation, and can do so in an efficient and cost-effective manner. For more information about the ways in which ML Solutions 4U's money laundering training can benefit your business, please complete our enquiry form or call an advisor on 0845 402 0001.

Money Laundering Information » Money Laundering Training and in House Guidelines