What this is
Keeping the licence. Supervision begins the day it is granted, and the obligations do not reduce.
What it involves
A reporting calendar that someone owns. Periodic regulatory returns. The annual independent AML audit. Policy reviews when the business or the rulebook changes. Variation applications when the activity set changes — which it will, and which is a permission rather than a notification.
The MLRO function
We support an in-house MLRO or provide the function where the structure permits it. Either way the role needs to be real: escalation that happens, decisions that are recorded, and a person who can answer a supervisor's questions without reading from a policy.
Why firms lose licences
Rarely for a single dramatic failure. Usually for a slow accumulation: a reporting deadline missed, a policy that stopped matching the business, an audit finding not closed out, a variation never applied for.
Régulateurs
Questions fréquentes
Can we handle compliance internally?
Many firms should, once they are large enough. Until then an outsourced or supported function is usually more effective than a part-time internal one, provided it is genuinely engaged rather than nominal.
Sources
- Scope of work described here reflects our practice, not a regulatory requirement — Regulatory statements on these pages carry the same review status as elsewhere on the site