We have been reviewing a number of money laundering policies recently and have listed some of the key areas that are often missed. We would recommend you consider whether your anti-money laundering policies cover the following points:
- When accounts should be frozen and a Defence Against Money Laundering (DAML) requested.
- The new de-minimis level of £1,000 for payments on accounts pending a response from the NCA to a DAML request (for more information click here)
- The requirement to check members for Politically Exposed Persons on an ongoing basis.
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- Checks against sanctions lists and reporting to the Office of Financial Sanctions Implementation
If you require any assistance with your policies or AML training then please get in touch with the Alexander Sloan team.