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JFSC findings from its MLRO thematic


The following are the areas firms should focus on when assessing their MLRO

  1. Lack of independent assessment conducted annually
  2. Training not specific and effectiveness not tested
  3. Staff encouraged to discuss concerns with line-manager or MLRO/DMLRO
  4. Inadequate processes and procedures
  5. Lack of understanding between MLRO and MLCO responsibilities
  6. Unclear decision-making process regarding SARs

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