Financial Crime20 min

Anti-Money Laundering Fundamentals

The core AML/CTF obligations every fund manager employee must understand — from risk assessment to reporting.

Your role in the first line of defence

Money laundering is the process of making the proceeds of crime appear legitimate. As a regulated firm, we are legally required to detect and deter it under the Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002.

Everyone at the firm is part of the control framework — not just the MLRO. Recognising and escalating concerns is a personal legal obligation.

Placement — introducing criminal cash into the financial system.
Layering — moving funds to disguise their origin.
Integration — returning laundered funds to the criminal as apparently clean money.

Illustration representing anti-money-laundering controls. — The three classic stages of money laundering.

Know your customer (KYC)

We must identify and verify every client, understand the purpose of the relationship, and apply ongoing monitoring proportionate to risk.

1Identify the client and verify their identity from reliable sources.
2Identify beneficial owners where the client is not an individual.
3Apply enhanced due diligence (EDD) to higher-risk relationships, such as PEPs.

Self-check

You notice a transaction that appears inconsistent with a client’s known profile. What should you do first?

Ignore it if the amount is small.Raise an internal report to the MLRO without tipping off the client.Ask the client directly whether they are laundering money.Freeze the account yourself immediately.

AML red-flags quick reference

A one-page checklist of common warning signs to keep at your desk.

PDF · sample file

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