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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 .
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