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

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05 Jan 2023
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On 19 December 2022, HM Treasury published the Anti-money laundering and countering the financing of terrorism: supervision report 2020-2022.

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.

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