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  • AML 9.4.1 AML 9.4.1

    An Authorised Person must ensure that its audit function, established under GEN Rule 5.3.13, includes regular reviews and assessments of the effectiveness of the Authorised Person's money laundering policies, procedures, systems and controls, and its compliance with its obligations in this AML module.

    Derived from RM117/2013 [VER9/07-13]

    • AML 9.4.1 Guidance

      1. The review and assessment undertaken for the purposes of Rule 9.4.1 may be undertaken:
      a. internally by the Authorised Person's internal audit function; or
      b. by a competent firm of independent auditors or compliance professionals.
      2. The review and assessment undertaken for the purposes of Rule 9.4.1 should cover at least the following:
      a. sample testing of compliance with the Authorised Person's CDD arrangements;
      b. an analysis of all notifications made to the MLRO to highlight any area where procedures or training may need to be enhanced; and
      c. a review of the nature and frequency of the dialogue between the senior management and the MLRO.
      Derived from RM117/2013 [VER9/07-13]