Text for CQS CPMS Policy
CQS Policy: What is ongoing monitoring?
Purchase this policy: Anti-Money Laundering Policy
- Change date
- 16/07/2025
- Word count
- 242
- Deployment measure
- 7/10
Rationale
The SRA are increasingly guiding firms that it is not enough for the AML Policy to have a specific section on ongoing monitoring, it must provide any detail in respect of how the firm satisfies regulation 28(11)(b).
We are required to undertake ongoing monitoring of business relationships. This means scrutiny of transactions, including where necessary, the source of funds to ensure that it aligns with the documentation
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