Internal controls
Contents
Internal controls
The level of internal controls and 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
 
Issues which may be covered in an internal controls system include:
- The level of personnel permitted to exercise discretion on the risk-based application of the 2007 Regulations, and under what circumstances
 - CDD requirements to be met for simplified, standard and enhanced due diligence
 - When outsourcing of CDD obligations or reliance will be permitted, and under what conditions
 - How the business will restrict work being conducted on a file where CDD has not been completed
 - The circumstances in which delayed CDD is permitted
 - When cash payments will be accepted
 - When payments will be accepted from or made to third parties
 - The manner in which disclosures are to be made to the MLRO