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

Copyright © 2021 Epoq Group Ltd. All trademarks acknowledged, all rights reserved

This website is operated by Epoq Legal Ltd, company number 3707955, whose registered office is at 2 Imperial Place, Maxwell Road, Borehamwood, Hertfordshire, WD6 1JN. Epoq Legal Ltd is authorised and regulated by the Solicitors Regulation Authority (SRA number 645296).