AML 4 MSB 3. Senior Managers

We have covered definitions of anti money laundering, terrorist financing, and money service businesses. In this post, we will define who is a senior manager, and what responsibilities they have with regards to The Regulations.

“A senior manager is an officer or employee who has the authority to make decisions that affect your business’s exposure to money laundering and terrorist financing risk. Examples can include a director, manager, company secretary, chief executive, member of the management body, or someone who carries out those functions, or any partner in a partnership, or a sole proprietor.”

An extensive definition. Why so broad? Well, as regulation evolved, it became apparent that senior managers felt that The Regulations were an issue for the Compliance department, and nothing to do with them. The definition clarifies that if you have a management role, then you have a responsibility.

Senior Managers must

  • conduct a risk assessment and manage AML/TF risk effectively
  • adopt a risk-based approach, ie; focus on the higher risks
  • appoint a nominated officer to report suspicious activity to the National Crime Agency (NCA)
  • devote sufficient resource to counter AML and TF


Senior Managers must

  • ensure risk assessment is carried out and documented
  • ensure written policies and procedures are prepared, maintained and approved’ to manage the risks identified above
  • ensure the policies and procedures are regularly reviewed and updated to reflect the evolving nature of the risks faced.

The reader will note the liberal use of the word “must”. That comes from the guidance, not from me. It is abundantly clear that this is meant to be taken seriously.

If you are a senior manager, you MUST ensure that The Regulations are being adhered to. “I thought Compliance was doing it” is not an acceptable defence.

At first, these responsibilities can appear daunting, but once the initial work is done, it is straightforward to maintain an effective regime.

Worried that you haven’t taken responsibility properly? Get in touch. Lime will conduct a review for you, free of charge.