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You are a newly appointed Money Laundering Reporting Officer (MLRO) at a medium-sized regulated financial services firm based in a jurisdiction of your choice.

The below assessment question needs to be answered from the perspective of the UK Jurisdiction. As a result, I`ve included several Reference material sources at the end which pertain to what needs to be referenced / included - ignoring the "required references" number. I would prefer avoiding including works outside of official legislation & compliance standards. I would very much hope should you need any clarification, please, contact me as soon as needed. The question requiring answering goes as follows:

You are a newly appointed Money Laundering Reporting Officer (MLRO) at a medium-sized regulated financial services firm based in a jurisdiction of your choice.
You have been asked by the Board of Directors to undertake a thorough review of the AML policies, procedures and culture prevalent in the firm.
A recent regulatory visit to the firm highlighted inadequate AML systems and controls. The board are concerned that the firm may suffer regulatory sanctions or negative publicity as a result.
Previously, the AML role has been fulfilled by the firm`s Regulatory Compliance Officer.
You conduct initial investigations and discover:
• the firm is expanding into the realm of providing complex investment and tax avoidance services for high-net-worth individuals (HNWIs).
• the Board has a high-risk appetite for business, particularly in jurisdictions that are high on the Transparency International Corruption Perception Index as jurisdictions where the levels of corruption are high.
• the Chief Executive Officer (CEO) of the firm encourages sales techniques that may not be in the best interests of the customers. The CEO was formerly the sales director. He has introduced substantial staff bonus payments tied to new business targets. This has resulted in a corporate culture where Customer Due Diligence (CDD) is conducted but there is a lack of enthusiasm for the process.
• the CEO has made it clear that whilst he appreciates that CDD must be conducted, staff should not let this unduly inhibit sales, particularly for the new HNWI customers
• the files you examine indicate that information about source of wealth and source of funds is often basic and is rarely independently verified.
• previously the Regulatory Compliance Officer (much to her annoyance) has had responsibility for AML within the firm. When interviewed she stated that she had `neither the time, nor the training to properly fulfil this role`. She commented that `the CEO is aggressive and everyone does what he says`. She further stated that had it not been for the regulatory report, the firm would not have appointed a new MLRO.
• where a new HNWI requests to become a customer the internal procedure is that the application has to be passed to the CEO for final sign-off. To date no HNWIs have been refused despite the fact that many originate from high-risk jurisdictions and often have military or government connections.

In the review paper you`ll need to cover:
• an assessment of the AML culture within the firm
• an analysis of the AML and CDD risks inherent in the way the firm is operated
• a schedule of recommendations to reduce AML and financial crime risk and better protect the firm.


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