The review found key challenges in transaction monitoring (TM), knowledge of the Suspicious Activity Reporting (SAR) glossary code, data sharing, and Customer Risk Assessment (CRA) methodology documentation.
Key actions for firms following the report:
- Business Wide Risk Assessments (BWRA): Ensure BWRAs and wider control frameworks consider and reflect MLTM risks;
- Training: Update firm wide and role specific training for staff to raise awareness of MLTM risks;
- Transaction Monitoring (TM): Tailor TM control systems and integrate them as part of your wider FCC framework;
- SAR Reporting: Ensure staff members involved in SAR reporting are familiar with the glossary code to submit accurate, high-quality SARs; and
- Information Sharing: Review the Economic Crime and Corporate Transparency Act (ECCTA) and consider ways to further share relevant information associated with the risks for MLTM.
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