Criminal Finances Act 2017

8

CRIMINAL FINANCES ACT 2017 | BDO UK

BDO APPROACH

FIRST STEP: RISK ASSESSMENT

PRACTICAL STEPS 1: POLICIES AND PROCEDURES

We have four options for the risk assessment depending on the size, complexity, existing financial crime framework and level of client resource :

Quick wins include the development of CCO policies, procedures, due diligence checklists etc that should be distributed across your business and to key internal and external stakeholders. We have developed a suite of CCO template policies that includes:

1. Full support CCO Risk Assessment o Training presentation o CCO Risk Assessment workshop

1. Board paper on CCO

o Review of your existing policies and procedures o Completion of your CCO Risk Register within full CCO report o Identification of key risk areas and recommended controls o BDO Opinion o Closing meeting to discuss next steps o Template policy documentation 2. Light touch support CCO Risk Assessment o Training presentation o CCO Risk Assessment workshop o Summary note of workshop findings, with key risks identified o CCO Risk Database and template CCO Risk Assessment o Template policy documents 3. Enabling your Risk Assessment o Training presentation o Provision of CCO risk database and template CCO Risk Assessment o Template policy documents

2. Internal ‘Instant Messaging’ within the business

3. CCO communications to Suppliers (for all Associated Persons)

4. CCO Policy – detailed internal overview of CCO

5. CCO Employee Code of Behaviour

6. Code of Conduct for Suppliers – CCO section

7. Agent Declaration

8. CCO contractual terms for suppliers

9. Supplier due diligence checklist

10. M&A due diligence checklist

4. Benchmarking existing CCO risk assessment .

Made with FlippingBook Learn more on our blog