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ML 6.2 Awareness

ML 6.2.1R

A relevant firm must take reasonable steps to ensure that staff who handle, or are managerially responsible for the handling of, transactions which may involve money laundering are aware of:

  1. (1)

    their responsibilities under the relevant firm's arrangements made under this sourcebook, including those for obtaining sufficient evidence of identity, recognising and reporting knowledge or suspicion of money laundering and use of findings of material deficiencies;

  2. (2)

    the identity and responsibilities of the MLRO or a person authorised by the Director General of NCIS;

  3. (3)

    the law relating to money laundering, including the Money Laundering Regulations and this sourcebook; and

  4. (4)

    the potential effect, on the relevant firm, its employees and its clients, of any breach of that law.1

ML 6.2.2E
  1. (1)

    A relevant firm should provide information, whether recorded in writing or otherwise, which:

    1. (a)

      covers the matters in ML 6.2.1 R;

    2. (b)

      is brought to the attention of any member of staff who starts to work in any capacity within a relevant firm which is covered by this sourcebook; and

    3. (c)

      remains available to that person so long as he works for that relevant firm in that capacity.

  2. (2)

    Contravention of (1) may be relied on as tending to establish contravention of ML 6.2.1 R.

  3. (3)

    Compliance with (1) may be relied on as tending to establish compliance with ML 6.2.1 R.

ML 6.2.3G

Staff need to have an awareness of anti-money laundering legislation in the United Kingdom, including a clear understanding of their own potential criminal liability.

ML 6.2.4G

Staff are likely to need information about the ways in which their clients' involvement in money laundering may affect bank and other accounts and other assets, in particular if a relevant firm decides it is unable to process transactions, because of the risk of committing a money laundering offence. They are also likely to need information about the ways in which the relevant firm may itself be at risk if (without the consent of NCIS) it processes transactions which involve the proceeds of crime.