Anti-Money Laundering Toolkit (4th edition)

This highly respected book is now in its 4th edition, which shows just how much has changed in the three years since the last one. No one tasked with AML compliance should be without this tried-and-tested staple. Indeed, seasoned money laundering reporting and compliance officers will need no introduction to the author and will no doubt already have replaced their dog-eared copy of the 3rd edition.

I found the Toolkit extremely readable. If I, with my lamentably short attention span, can devour it cover to cover on a two-hour train journey, anyone can. A time-poor lawyer, I am drawn to its lean, no-nonsense approach.

There is a complete library of highly practical templates (downloadable, so no need now for CD capability) and there are helpful notes on how and why those templates could be used. This functionality will be especially useful not only to AML leaders (who may like to use the book as a gap-analysis tool for reviewing existing provision), but also to newcomers to the AML compliance role, who may need to put in place an entire suite of documents. They will find a smorgasbord of draft policies, controls and procedures ready to be tailored to their specific needs.   

Highlights for me include: the template Risk Assessment Matrix (which sets out typical work types explaining why they are, or are not, high-risk); the ongoing monitoring procedure (providing the vital details of the ‘how we do it here’ – lack of ongoing monitoring evidence being in my experience a frequent flyer in file review non-compliance); and the discussion of how to exit the client relationship where there are AML concerns, in chapter 7.

Given the recent SRA thematic review of AML training, the highly practical suggestions in chapter 8 will be of particular interest to MLCOs and COLPs.

In a word, indispensable.

Fiona du Feu spent over 20 years in private practice. She now runs her own risk and compliance consultancy for lawyers