Your AML systems produce reports showing what you did. But what happens when a client you onboarded 4 years ago goes rogue today? Suddenly your historical processes are under scrutiny.
Can you prove what you knew?
Can you demonstrate why you decided what you decided was appropriate?
If the reasoning isn't already documented, you don't get a chance to explain — you get a finding.
With FCA taking over MLR supervision, you're more likely to be reviewed on AML than on your actual regulatory space
Your exposure goes back 5 years. The FCA can review your entire client history.
Directors are liable for systems and controls (Reg 21) — you cannot delegate this accountability
MLROs face personal liability under POCA (up to 5 years imprisonment)
Your exposure goes back 5 years
For Directors
Who cannot delegate their Reg 21 liability for systems and controls.