4MLD – updating the AML policy

Our CDD (client due diligence) or KYC (know your client) needs to be reviewed and tightened up. From 26th June 2017, the 4th Money Laundering Directive (4MLD) should be brought into effect by The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

There is more of a risk-based emphasis in 4MLD, with a greater requirement to keep a record of risk assessment. For example, I have flagged up to my colleagues that we need to ensure that our client opening form reflects our consideration of this issue in the allocated box. Also, there are new things like ensuring we have id for Donors on Settlements.

Something to consider reviewing in your firm now, prior to the new Regulations coming into force…

I found this summary by VinciWorks very helpful http://vinciworks.com/blog/4th-money-laundering-directive-what-you-need-to-know/#comment-3454

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