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