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Internal controls

Internal controls

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

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