Posts

Showing posts with the label AML Compliance

DAML Requests in the UK: What Makes a Request Complete

AML Compliance in the UK and Europe: What Makes a DAML Request Complete A defence against money laundering request is simple to describe and easy to get wrong. A firm that suspects a planned transaction involves criminal property asks the UK Financial Intelligence Unit for a defence to carry out that specific act. What the unit receives decides how quickly, and whether, it can respond. In short: a complete DAML request explains the suspicion, describes the property and sets out one future, specific act. A request missing any of these can be questioned or closed. The three essentials Essential What it means Grounds for suspicion The facts and reasoning behind the suspicion, in clear language. The property What you suspect is criminal property, with a value and, where known, a location. The prohibited act The future, specific activity you want a defence to carry out. How the clock works The notice period starts on the first working day after submission and runs fo...

Who Expects What From Your SARs: The NCA, the FCA, JMLSG and the Law

UK AML and Europe: Who Expects What From Your Suspicious Activity Reports Ask four people in a financial crime team who sets the standard for a SAR and you may get four different answers. The law, the NCA, the FCA and the industry guidance each play a part, and they do different jobs. In short: the law creates the duty, the NCA receives and uses the reports, supervisors check your systems, and industry guidance shows what good looks like. Who What they do for your SARs The law SARs come from section 330 of the Proceeds of Crime Act 2002, not from the 2017 Money Laundering Regulations. The Regulations require a nominated officer and procedures. The NCA Receives reports through the UKFIU, publishes guidance and decides what to do with what it receives. The FCA Supervises the systems and controls of the firms it regulates, including how they identify and escalate suspicion. JMLSG Publishes industry guidance for the financial sector that supervisors generally treat as a ben...