AML - the size and nature test

Regulation 21 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 requires that a firm which is regulated, implements internal controls where appropriate to the size and nature of the firm. These controls are: 1. Appoint a person to be responsible for compliance with the regulations. 2. Screen relevant employees, both before the appointment is made and ongoing thereafter. 3. Establish an independent audit function So, what should the ‘controls’ look like and what is the appropriate ‘size and nature’? Controls In my experience, in legal services we don’t have many controls in place. Our colleagues in other industries, such as financia

What's your goal?

At the start of 2018 most us will have sat down and set personal new year resolutions. There are two questions I would ask: How many of those resolutions are you maintaining? Out of those resolutions, were any of them business focused? Whether you are the decision maker in the firm or an employee it is always good to have goals to focus on. Compliance underpins both the individual and firm wide goals, without it you are almost certainly not going to succeed. At the very least whilst you may think you are succeeding without compliance, it will only take one complaint that leads to a negligence action or a rogue fee earner that will bring the walls tumbling down. The foundation of any la

What’s a DPO and does my business need one?

‘DPO’, or Data Protection Officer is the person in a business who has been appointed to deal with all data privacy related matters. Under the current Data Protection Act there are no mandatory requirements to appoint a DPO, although some businesses that process a high volume of data may have someone in that role already. There has been a lot of confusion over the last few months about whether the implementation of GDPR [1] (on 25th May 2018) or the introduction of the Data Protection Bill 2017 means that businesses do now have to appoint a DPO. The answer to that question is, no, not all businesses need to appoint a DPO BUT that doesn’t necessarily mean that it’s not in your business' best

Know your clients to avoid penalties

I was recently at an event speaking about anti- money laundering legislation. As my attentive audience sat eagerly taking notes, one delegate raised her hand to ask about client verification, and the how's of doing it correctly. Silence struck the room quite quickly as the realisation hit all the delegates - this was something they needed to consider and manage effectively. It sounds straight forward but get it wrong or miss something and the penalties to your business can be steep. The easiest, cost effective option, by which to verify your clients is E- verification. Nowadays E-verification is a viable option used by many corporate firms that are looking to streamline an alread

GDPR – ICO Fee Changes from 1st April 2018

As we are all aware, the GDPR implementation deadline of 25th May 2018 is fast approaching….. in fact it’s just over 15 weeks away. But were you also aware that the requirements for data controllers to register with the ICO, and the fees for registration are changing on 1st April 2018? Under the current rules, organisations that process personal information are required to register (notify) with the ICO as data controllers. The notification includes explaining what personal data they collect and what they do with it. At the point of notification, the data controller is required to pay a fee, currently £35 per year for organisations with less than 249 employees, and £500 for all other orga

No rest for the wicked – or the rest of us!

The wicked, the criminals, are continuously innovating, and creating new ways to make money out of crime. They are also money laundering, on an epic scale. The scale of money laundering in the UK is thought to be £90bn a year. 2017 was a year of change in AML and financial crime, with the long awaited Money Laundering, Terrorist Financing, Transfer of Funds (Information on the Payer) Regulations 2017 (MLR), and the Criminal Finances Act. There was plenty to think about and do. But it doesn’t stop there. The wicked don’t, so we can’t. Here are 4 things you will need to tackle in 2018. 1. Final Guidance The Legal Sector Affinity Group have prepared guidance for firms on MLR 2017,

COLPs New Year's Resolutions (in February)

So it's been back to the coal face for a month now since the Christmas festivities. How are you getting on with your resolutions? Like a lot of people you may have made resolutions to mark the New Year. Research (credit a quick google search) suggests only 8% of people keep them. Why is that? Opinions vary from they are unattainable (lose 70lbs by March), unrealistic (give up wine) or hard work (run 1000 miles this year). I kept one for a while, in 1987 I became a vegetarian and lasted until 2006! Let's take this resolution - I will take steps to ensure that the firm is compliant (if you're the COLP that one is in the authorisation rules). It hopefully isn't unattainable or unrealistic, but

The 'Compliance' word

The mere mention of the “C” word tends to fill people with dread and many firms, Partners or owners continue to bury their heads in the sand. Many firms have changed the structure of their business support showing that there is a significant shift from the misconception of “fee burners” and “fee earners”. Firms have no choice but to become pro-active to ensure that compliance is embedded into the culture of the firm, with employees knowing and understanding the beliefs and values of the firm they are working for. Invest in business support to drive the firm in the right direction. Compliance is an essential element of your firm's foundation to succeed. It is not about how many accreditat

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