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.
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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.
Kaynaklar
- 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