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Money Laundering (Legislation (EU's Money Laundering Directive (Fourth…
Money Laundering
Legislation
Proceeds of Crime Act 2002
Principals
Concealing criminal property
Arranging
Acquiring, using or processing
The Terrorism Act 2000
EU's Money Laundering Directive
Third Money Laundering Directive
Conversion/transfer of property from criminal activity
Conceal/disguise from criminal activity
Acquisition, possession, or use from criminal activity
Participating/commissioning criminal activity
Fourth Money Laundering Directive
Identification threshold 10k
Adopt risk based approach
Wider definition of 'politically exposed persons'
Inclusion of 'tax crimes'
Strong EU co-operation
Transparency of 'beneficial ownership entities'
Money Laundering Reporting Officer
Appropriate Seniority
Calendar year reporting
Staff Reporting
Suspicious activity reports (SARs)
Customer Due Diligence
Identification Procedures
New business relationship
Occasional transaction exceeding 15k
Life assurance polices
Annual premium exceeds 1k
Single premium 2500
Suspicion
Doubts
Change of circumstances
Acceptable Forms of ID
Current passport
National identity card with photo
Driving license with photo
Entry on electoral roll
Utility bill/council tax bill
FCA Sourcebook
Senior Management Systems and Controls (SYSC)
Accountabilities, procedures, and systems
Senior manager responsibilities
Money laundering reporting officer (MLRO)
Documented rick policy
Regular staff training
Procedures are up to date
MLRO report each year
Remedied deficiencies on reports
The Bribery Act 2010