Monitoring compliance

The extent to which monitoring needs to take place will be affected by:

• The size of the business
• The nature, scale and complexity of its operations
• Its overall risk profile

Monitoring compliance will assist a business to assess whether the policies and procedures it has implemented are effective in forestalling money laundering and terrorist financing opportunities within the organisation. Issues which may be covered in a compliance system include:

• Procedures to be undertaken to monitor compliance, which may involve:
• Random file audits
• File checklists to be completed before opening or closing a file
• An MLRO's log of situations brought to their attention, queries from staff and reports made
• Reports to be provided from the MLRO to senior management on compliance
• How to rectify lack of compliance, when identified
• How lessons learnt will be communicated back to staff and fed back into the risk profile of the business