Further expanding in this arena to financial crime; many firms continue to refine implementation of the 2017 Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (‘MLR’) from 2017. The impending regulatory updates which expand scope and responsibilities could expose individuals to the risk of criminal proceedings, if not adequately managed. Into 2021, firms must ensure they are well positioned to comply with requirements to protect their business and clients and to mitigate this newly introduced personal risk. Under pandemic conditions, there have been some limitations on the traditional processing approach introduced through dispersed working. Going into 2021 and with the continuation of this working environment, firms should mitigate risk by ensuring that they are addressed on a more permanent and robust basis, to alleviate inadvertent and undue exposure in the MLR and customer due diligence (‘CDD’) space, which is a fundamental requirement to business operating. Whilst the pandemic has introduced a blanket operating risk for firms, business operations have moreover continued and firms have adapted, rising to the challenges presented in these areas. Into 2021, firms should remain vigilant, agile, objective and alert in their management of risk. This should put them in position to continue to mitigate against the risks of an ever changing environment, increased regulatory obligations, the growing sophistication of cyber criminality and the real life testing of operational resilience, including as a result of greater supplier reliance that dispersed working brings.
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