You are required by law to conduct ongoing monitoring on your matters. You do this as part of the Risk Questionnaire and your narrative client/matter risk assessment on inception and thereafter, you must monitor the matter and keep your narrative client/matter risk assessment up to date. If you have any concerns about the matter of any nature, you must alert the MLRO. Otherwise you should simply note relevant developments on the matter that have a money laundering impact, but which do not increase the risk profile of the matter.
You must ensure that:
If any of the following apply, you should call the MLRO without delay:
About the client
About funds
About the matter
For a full list of Red Flags, see the Anti-Money Laundering Red Flags document.
You must be vigilant and diligent in this regard as the possibility of financial crime must be treated as a real concern. You should have a reasonable understanding of a client's business and not simply carry out client instructions without understanding the rationale behind them. If you become suspicious of any activity undertaken by a client, then you must contact the MLRO. A quick telephone call can often deal fully with any unease you may have. If not, you will need to report the matter formally, but only once you have been given suitable guidance over the phone. The MLRO will take appropriate action including, if necessary, reporting the matter to the relevant authority. If you make a report, you will receive a receipt and guidance on what to do and of course what not to do.
On higher risk matters there is a formal internal review process overseen by the MLRO. Checks will be made by email and phone at appropriate intervals to the matter and not less than every three months to ensure nothing out of the ordinary has occurred. Naturally, it is especially important with a higher risk matter that you immediately report to the MLRO or Director of Operations and Compliance any suspicious patterns or behaviour of concern.