The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) (referred to as the 2017 MLRs hereafter), sets out in Regulation 21 details of internal controls.
Section (1) (b) states that a relevant person must carry out screening of relevant employees appointed by the relevant person, both before the appointment is made and during the course of the appointment. Section (2) explains that “screening” means an assessment of:
the skills, knowledge and expertise of the individual to carry out their functions effectively;
the conduct and integrity of the individual
The purpose of the template questionnaire and declaration set out below is to assist Members-in-Practice comply with these specific requirements of the 2017 MLRs.
In addition, Regulation 24 of the 2017 MLRs requires that staff (and subcontractors) are subject to adequate training. Records of training conducted are required to be maintained and the declaration set out below helps record staff acknowledgements that they have received training and understand their obligations. Staff training records should be documented, signed and updated on an annual basis.
It is anticipated that the template set out below will be completed at commencement of employment and on an annual basis thereafter.