When you do things from your soul, you feel a river moving in you, a joy. Rumi
Idea Transcript
AML/CTF and sanctions risk assessment procedure Purpose This procedure sets out how [legal practice name] will assess the risks of being involved in money laundering or terrorist financing or breaching sanctions requirements. Application This procedure applies to senior management, the MLRO and the COLP. Initial risk assessment The [board/partnership/management team/other], MLRO and COLP will identify, assess and record the AML/CTF and sanctions risks applicable to [legal practice name] using [the risk identification matrix/other]. Taking into account the risks identified, the [board/partnership/management team/other], MLRO and COLP will complete the risk mitigation form, setting out how the legal practice will meet its regulatory and legal obligations. The [COLP/MLRO] will ensure that this information is added to the risk register and compliance plan for [legal practice name]. Ongoing risk assessment The [board/partnership/management team/other], MLRO and COLP will review the risk profile of the legal practice whenever [legal practice name] considers any significant change to its business model, including:
merging with or taking over another legal practice; entering into a referral arrangement or best-friend relationship with another organisation; opening a new office; undertaking a new area of practice; seeking clients from a new jurisdiction or a new domestic market with links to a foreign jurisdiction.
The MLRO will review the risk profile of [legal practice name] during the preparation of the MLRO report to management. The MLRO is required to keep the high-risk country checklist updated and ensure systems are in place to check whether clients are on the sanctions lists before monies are received from or sent to clients. Communication to employees The completed risk profile of [legal practice name] and the high-risk country checklist will be made available to all employees of [legal practice name] through the [AML manual/intranet/other]. Related policy Anti-money laundering, counter-terrorist financing and sanctions compliance policy Risk assessment procedure etc