ANNUAL MONEY LAUNDERING REPORTING OFFICER REPORT

Authorised/Licensed Firms Nme!

"FC Num#er!
Re$ortin% Period!
Finnci& Yer End!
Dte o' su#mission to (enior Mn%ement!
Adequacy and effectiveness ) AML/CFTR *+,+- .*/
1. The report must assess the adequacy and effectiveness of the Firms AML/CFT policies,
procedures, systems and controls in preventin money launderin and terrorist financin.
The AML/CFT $o&icies0 $rocedures0 s1stems nd contro&s re!
Adequate !artially adequate "ot adequate "ot assessed yet
Comments! (How the adequacy assessment was conducted, areas of inadequacy)
The AML/CFT $o&icies0 $rocedures0 s1stems nd contro&s re!
#ffective !artially effective "ot effective "ot assessed yet
Comments! (How the effectiveness was assessed, areas of ineffectiveness)
Suspicious Transaction Reports ) AML/CFTR *+,+- .,/ ./0 .#/ 2 .c/ 3 .in &ine 4ith
Ch$ter 5/
$. The report must include%
a. the num&ers and types of internal suspicious transaction reports made to the ML'(
&. the num&er of these reports that have, and the num&er of these reports that have
not, &een passed on to the F)*
c. the reasons +hy reports have or have not &een passed on to the F)*
Intern& (TRs mde to the MLRO
,es "o
Comments!
I' 1es0 the num#er 2 t1$e.s/ o' Intern& (TRs mde to the MLRO
Comments! (detail the type of reports refer to the FIU uide to !"#$F %uspicious
$ransaction &eportin'()
Intern& (TRs $ssed to the FIU
,es "o
Comments!
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ANNUAL MONEY LAUNDERING REPORTING OFFICER REPORT
I' 1es0 the num#er o' Intern& (TRs nd reson.s/ 4h1 the Intern& (TRs h6e #een
$ssed to the FIU
7s the Re%u&tor in'ormed in 4ritin% tht the Firm hs mde re$ort to the FIU s
$er AML/CFTR 5+8+9.:/;
Comments!
I' no0 the num#er o' Intern& (TRs nd the reson.s/ 4h1 the Intern& (TRs h6e not
#een $ssed to the FIU
Comments!
Breach reports ) AML/CFTR *+,+- .,/ .d/
-. The report must include
d. the num&ers and types of &reaches &y the firm of the AML/CFT La+, these rules, or
the Firms AML/CFT policies, procedures, systems and controls
The num#er o' #reches #1 the Firm o' the AML/CFT L40 the AML/CFT Ru&es *<8<0
or the 'irms AML/CFT $o&icies0 $rocedures0 s1stems nd contro&s
Comments!
The t1$e o' #reches #1 the Firm o' the AML/CFT L40 the AML/CFT Ru&es *<8<0 or
the Firms AML/CFT $o&icies0 $rocedures0 s1stems nd contro&s
AML/CFT La+ AML/CFT' Firms AML/CFT
policies, procedures,
systems and
controls
(ther
Comments! (article#section#division, reasons, remediation action, prevention plan)
Improvements ) AML/CFTR *+,+- .,/ .e/
.. The report must include%
e. areas +here the Firms AML/CFT policies, procedures, systems and controls should
&e improved, and proposals for ma/in appropriate improvements
Are.s/ o' im$ro6ement
!olicies !rocedures 0ystems Controls no need for
improvement
Comments! (how the areas of improvement were identified, what were they)
Pro$os&.s/ 'or m=in% $$ro$rite im$ro6ements
Comments! (type of improvement, action plan#timeframe, resources needed, senior
mana'ement en'a'ement)
$
ANNUAL MONEY LAUNDERING REPORTING OFFICER REPORT
Training ) AML/CFTR *+,+- .,/ .'/ 2 .%/ ) in &ine 4ith Prt :+* AML/CFTR
1. The report must include%
f. a summary of the AML/CFT trainin delivered to the firms officers and employees
. areas +here the Firms AML/CFT trainin proramme should &e improved, and
proposals for ma/in appropriate improvements
The Firm hs ensured tht n $$ro$rite trinin% $ro%rm hs #een de&i6ered to its
em$&o1ees
,es "o
Comments! (how did the firm determine whether the trainin' was appropriate ) ali'ned with
*!"#+F$& ,-.-/0 if no, why not, what is the remediation plan0)
The Firm hs de&i6ered AML/CFT trinin% $ro%rm to!
the totality of the
Firms employees
most of the Firms
employees
to a fe+ num&er of
the Firms employees
AML/CFT trainin
proram has not &een
delivered to the Firms
Comments! (who received the trainin'0 who did not0 why not0 remediation pro'ram in
place)
(ummr1 o' the AML/CFT $ro%rmme
Comments! (summary of the pro'ram, how did the pro'ram assist the Firm in dischar'in' its
o1li'ations under *!"#+F$& ,-.-/(.))
Ares 4here the Firms AML/CFT trinin% $ro%rmme shou&d #e im$ro6ed
,es "o areas to improve
Comments! (if yes, what are they0)
Pro$os&s in $&ce 'or m=in% $$ro$rite im$ro6ements
,es "o proposals
Comments! (if yes, what are they0)
High Risk customers ) AML/CFTR *+,+- .,/ .h/ ) in &ine 4ith Ch$ter ,
2. The report must include
h. the num&er and types of customers of the firm that are cateorised as hih ris/
Customers o' the Firm cte%orised s hi%h ris= 'rom AML/CFT $ers$ecti6e
,es "o hih ris/ customers
Num#er o' hi%h ris= customers!
Comments! (further details)
-
ANNUAL MONEY LAUNDERING REPORTING OFFICER REPORT
I'0 1es0 the t1$e o' customers o' the Firm tht re cte%orised s hi%h ris= 'rom
AML/CFT $ers$ecti6e
)ndividuals Corporate Financial
)nstitutions
(ther
Comments! (further details)
Assessment o' the Firms ."FC entit1/ AML/CFT ris=
3ih Medium Lo+ AML/CFT ris/ not
assessed yet
Comments! (refer to *!"#+F$& 2-/-/ for further details)
The Firms $$roch to miti%te the AML/CFT ris= tht it 'ces
Comments! (refer to *!"#+F$& 2-/-.)
Action Plans ) AML/CFTR *+,+- .,/ .i/
4. The report must include%
i. proress in implementin any AML/CFT action plans
The ction $&n 4s su#se>uent to!
The AML 0elf
Assessment
The !revious
Annual ML'( report
A 'is/ Assessment
5isit underta/en &y
the reulator
(ther
Comments!
Pro%ress in the ction $&n im$&ementtion
Item Pro%ress mde
- -
- -
- -
- -
- -
- -
- -
- -
Quality Assurance ) AML/CFTR *+,+- .,/ .?/ ) s $er AML/CFTR *+8+8 .d/ 2 *+*+* .d/
'or e@m$&e
6. The report must include%
7. the outcome of any relevant quality assurance or audit revie+s in relation to the
Firms AML/CFT policies, procedures, systems and controls
.
ANNUAL MONEY LAUNDERING REPORTING OFFICER REPORT
T1$e o' inde$endent re6ie4er
)nternal audit #8ternal audit )ndependent
revie+ &y Compliance
(ther independent
revie+er
Comments! (period, e3aminers, scope, methodolo'y, !"&4 ) %enior mana'ement comments
on the findin's, action plan )
Outcome o' inde$endent re6ie4s
Findin% Action P&n
- -
- -
- -
- -
Risk Assessment outcomes ) AML/CFTR *+,+- .,/ .=/
9. The report must include%
/. the outcome of any revie+ of the Firms AML/CFT ris/ assessment policies,
procedures, systems and controls :other than the one mentioned in the previous
section;
T1$e o' re6ie4er o' the 'irms ris= ssessment $o&icies0 $rocedures0 s1stems nd
contro&s
ML'( #8ternal consultant (ther internal
revie+ers
(ther e8ternal
revie+ers
Comments! (period, e3aminers, scope, methodolo'y, !"&4 ) %enior mana'ement comments
on the findin's, action plan )
The outcome the re6ie4 o' the Firms AML/CFT ris= ssessment $o&icies0 $rocedures0
s1stems nd contro&s
Findin%s Action P&n
- -
- -
- -
- -
Other mtters
Comments!
0u&mitted <y%
="ame of ML'(, Authorised/Licensed
Firm>
?ate%
0ined%
1
ANNUAL MONEY LAUNDERING REPORTING OFFICER REPORT
Senior anagement consideration ) AML/CFTR *+,+A
1@. The 0enior Manaement of a Firm must, +ithin . months of the year endA
a. consider each report made to it &y the ML'(B and
&. if the report identifies deficiencies in the Firms compliance +ith the AML/CFT La+ or
these rulesAapprove an action plan to remedy the deficiencies in a timely +ay
:$.-.9;
(enior Mn%ement considertion o' the re$ort
,es "o
(enior Mn%ements comment.s/!
(enior Mn%ement $$ro6& o' n ction $&n to remed1 the de'iciencies in time&1
41
,es "o "ot applica&le
Comments! (what are these action plans, what are the resources allocated for
implementation, what are the deadlines set)
Areed <y%
="ame of 0#F/ 0enior Manaement of
Authorised/Licensed Firm>
Title%
?ate%
0ined%
2