Compliance checklist
Make sure you're compliant with the Money Laundering Regulations 2007. This checklist covers the key information areas that regulated businesses must provide for both their existing and prospective customers.
Can you answer 'yes' to all 10 questions below?
01. Do you have a properly defined risk-based money laundering policy that outlines the extent of customer due diligence measures required, based on risk assessment and depending on the type of customer, business relationship, product or transaction? Does your policy outline procedures for taking on new customers that include details of a) how you will identify the business or individual, b) how you will confirm the identity of a business or individual and c) how you will carry out checks against relevant sanctions or PEP lists?
02. Do you know how will you implement or structure procedures to support your policy, ensuring it is consistently applied in all cases? In particular do you know what arrangements have been made, in practical terms, for “simplified” or “enhanced” due diligence?
03. Can you find out the registered name and address of each business as well as the trading address?
04. Can you find out the names of those with a controlling interest in the businesses, i.e. directors, and know their background?
05. Will you be able to identify the business owners, i.e. those with a beneficial interest of 25% or above?
06. Do you know how the necessary checks on those with a controlling interest, or beneficial stake, will be carried out?
07. Are you able to identify the corporate structure of the business, i.e. is it a subsidiary of a multinational business or standalone? If it is part of a complex corporate structure, what wider investigation can you make into the corporate hierarchy?
08. Do you know the nature of the business?
09. Do you know if there are any other credible third party sources you can use in order to triangulate the identification of the business, i.e. central regulators or exchanges?
10. Are you able to document and archive the identity checks you carry out so you can provide proof at any point that your checks meet the requirements of your risk based policies and procedures? Also do you have procedures in place for ongoing monitoring of all ten points mentioned above?
As a regulated business, you should be able answer 'yes' to all these questions to satisfy yourself that you are compliant. If you are considering outsourcing to an electronic data provider for verification, as suggested by the Joint Money Laundering Steering Committee's Final Consultative Text, revised in November 2007, you need to be confident that the data provider gives you all the information you need - in the correct format - in order to satisfactorily answer 'yes' to these ten points.
To understand how D&B can help you say 'yes' please contact Malcolm Parker for information about D&B's AML and KYC reports.
Please contact us to discuss your requirements
Decide with confidence today. For more information on D&B’s Enterprise Risk and Compliance Solutions, call 0800 001234 or email