Anti-money laundering and countering the financing of terrorism: supervision report 2020–22

Key findings include the most common breaches reported by legal public body supervisors (PBSs):

• inadequate documented policies and procedures
• inadequate customer due diligence (CDD) procedures
• inadequate enhanced due diligence (EDD) procedures
• no ongoing CDD monitoring
• no periodic review of compliance with money laundering regulations
• inadequate firm-wide risk assessment
• no or inadequate staff training on anti-money laundering (AML) compliance
• inadequate record keeping
• use of third-party policies that were not adequately tailored to the specific firm’s individual risk profile
• inadequate resource allocated to AML compliance

Many PBSs also noted that non-compliance and poor AML procedures were most common with smaller firms and sole practitioners, who often failed to understand the importance of having adequate AML controls in place.

A long-standing relationship between a client and a business leading to insufficient checks was also noted by many PBSs as being a common theme among non-compliant members of their supervised population.