enable it to identify, assess, monitor and manage money laundering risk; and
are comprehensive and proportionate to the nature, scale and complexity of its activities.
A common platform firm may also have separate obligations to comply with relevant legal requirements, including the Terrorism Act 2000, the Proceeds of Crime Act 2002 and the Money Laundering Regulations. SYSC 6.1.1 R and SYSC 6.3.1 R to SYSC 6.3.10 G are not relevant for the purposes of regulation 3(3) of the Money Laundering Regulations, section 330(8) of the Proceeds of Crime Act 2002 or section 21A(6) of the Terrorism Act 2000.
The FSA, when considering whether a breach of its rules on systems and controls against money laundering has occurred, will have regard to whether a common platform firm has followed relevant provisions in the guidance for the United Kingdom financial sector issued by the Joint Money Laundering Steering Group.
A common platform firm should ensure that the systems and controls include:
appropriate training for its employees in relation to money laundering;
appropriate provision of information to its governing body and senior management, including a report at least annually by that firm's money laundering reporting officer (MLRO) on the operation and effectiveness of those systems and controls;
appropriate measures to ensure that money laundering risk is taken into account in its day-to-day operation, including in relation to:
appropriate measures to ensure that procedures for identification of new customers do not unreasonably deny access to its services to potential customers who cannot reasonably be expected to produce detailed evidence of identity.
A common platform firm must: