Due diligence checklist, United Kingdom

MLR 2017 and NCA reporting: what to ask a vendor

Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. FCA and the NCA. Customer due diligence, monitoring and suspicious activity reporting meet the Regulations and JMLSG guidance.

A starting point, not legal advice. The regulator's own page: FCA and the NCA.

What it is

Customer due diligence, monitoring and suspicious activity reporting meet the Regulations and JMLSG guidance.

Who it applies to

Applies to every financial institution in the United Kingdom, when procuring financial crime and fraud, payments, core banking, digital banking.

What to ask a vendor, and the evidence to request

#Ask the vendor forEvidence to request
1Customer due diligence and enhanced due diligence to the Regulations and JMLSG guidanceThe identification and verification methods supported, the rules they follow, and the record kept for each check.
2Suspicious activity reports to the NCA, with defence against money laundering requestsA description of the reports the system produces for the regulator, the formats, and how they are lodged, with a sample.
3Screening against the OFSI consolidated listThe screening lists in use, how often they are updated, and a sample of the screening record a case produces.

In every case

  • A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
  • Which named customers the vendor already serves under this regime, as references you may call.

This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.

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