Virtuous Circle Model

Apr 9th '21

Need a dedicated resource who are professionally qualified and have years of industry experience in ensuring firms meet their legal and regulatory obligations?


The areas in which we offer our expertise covers the entire range of corporate responsibility in AML and Financial Crime.


Business Wide Risk Assessment


The Money Laundering Regulations and predicate legislation are more prescriptive regarding the approach firms should take to managing risk.


A formal and regular process to identify and assess the potential money laundering, terrorist financing and predicate crime risk. Taking into account of its products and services, types of clients, the jurisdiction it operates in, the complexity and volume of transactions and the delivery channels it uses. The broader objective of the risk assessment is to point the way to proportionate controls to mitigate and manage the identified risks.


The specific purpose is to determine the appropriate due diligence measures reflecting the type of client, business relationship, product of transaction involved.


Policies & Procedures


The regulated firm is required to establish and keep a written record of AML/CTF and predicate crimes (such as Fraud, Bribery & Corruption, Tax Evasion, Sanctions, Cyber Crime etc.) policies & procedures to mitigate and manage effectively the risks identified.


Where regulated firms can demonstrate they have robust, up-to-date policies & procedures, they will have a defence against a regulatory and criminal action.




There is a greater emphasis within the Money Laundering Regulations and predicate legislation on appropriate internal controls to offset the specific risks faced by the business.

Dependant on the size and nature of the business, specific requirements include appointing a board member to be responsible for anti-money laundering/ counter-terrorist financing and predicate crimes compliance, carrying out screening of employees, and establishing an independent audit function.


In addition to appointing a Nominated Officer, all regulated firms must inform their supervisory authority of the identities of the person responsible for compliance and the Nominated Officer within a specific period.




Under the Money Laundering Regulations and predicate legislation, training is mandatory. It must cover specific risks to your business on how to detect, mitigate and report against money laundering, terrorist financing, bribery & corruption, fraud and any other relevant predicate crimes identified within your Business-Wide Risk Assessment.


Your staff must receive ‘regular training’ on how to recognise and deal with transactions and other activities which may relate to money laundering, terrorist financing and predicate crimes.




A process for reporting Internal and External Suspicious Activity Reporting, to mitigate and manage the firm’s exposure to the business conducted and risks identified within the Business-Wide Risk Assessment.


Senior Management must take an active role in the anti-money laundering, counter-terrorism financing and predicate crimes by receiving regular and commissioning specific reports.



The Virtuous Circle Model


Five simple steps to ensure your business is protected from Financial Crime




Whatever regulated sector you operate in, we’ve teamed up with FinCrime Protection to provide a professional service to ensure you meet your regulatory requirements.


For further information please contact us where our industry experts will be happy to answer your questions.


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