Annual MLRO report 

Following the recent round of FCA thematic reviews of Anti Money Laundering AML Controls, IFAC have introduced automated AML reports.

Using IFAC's software BAT, the system will pick up the minimum requirements and request confirmation from the firm's CF11 that these procedures are in place.

All firms should download these reports from BAT and save before the end of February.

IFAC introduced the  AML reports following a recent FCA interview with one of their firms.   

The visit was a relatively straightforward  Anti money Laundering thematic review visit by the FCA to a small IFAs firm.

The format went something like this.

<> FCA MAN 

So you use a risk based approach? (oh good!)

IFA REPLY

Yes

FCA MAN

Have you filed suspicious activity reports?

IFA REPLY

No – we haven’t had any suspicious activities.

FCA MAN

What are the key issues in your latest MLRO report and what issues did they highlight?

IFA REPLY

Not as well documented as it should be….but we did a review.

FCA MAN

Were any PEPs found?  

IFA REPLY

No, we found no PEPs.

FCA MAN

So you never completed a AML Report?

IFA REPLY

No.

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So mindful of the question in bold above.... IFAC have hastily put together an Anti Money Laundering Report document onto BAT for you to complete and download for your own firm.

This is a major step forward in self–service compliance!

We urge all IFAs and MGI firms and indeed all other FCA regulated firms, to undertake the brief questionnaire that is required to generate the report. See diagram shown of the BAT system. 

Bat is a complete practice management system, as used by hundreds of firms.  Available here for £25 per month per RI plus vat.