Monitoring compliance

Monitoring compliance


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

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