AML/CTF Controls

Are your controls robust enough to survive an FCA visit? Can you verify and substantiate your conclusions? Are you confident that your business colleagues robustly apply compliance procedures to the satisfaction of FCA and can justify their action if interviewed?

The FCA’s ‘intensive and intrusive’ approach to supervision is having a significant effect on every individual who is a touchpoint for AML, ABC and CTF.  FCA’s recent financial crime thematic review has highlighted the importance of ensuring financial crime systems and controls are strong. In particular FCA found poor levels of awareness amongst relevant staff tasked with the prevention of financial crime including MLROs.  This workshop will use the  examples of action taken against firms who were chosen for the thematic review and apply the “lessons learned”.

Throughout this introduction to intermediate-level workshop delegates will be able to test and subject their own AML/CTF/ABC regime to a stringent evaluation. Delegates have the opportunity to benchmark their progress against other regulated firms and ensure that they have the most updated systems and controls – in the light of the significant challenges from regulators, policy makers, and law enforcement.

Throughout this introduction to intermediate-level workshop, delegates will be able to test and subject their own AML/CTF/ABC regime to a stringent evaluation.  Delegates have the opportunity to benchmark their progress against other regulated firms and ensure that they have the most updated systems and controls – in the light of the significant challenges from regulators, policy makers, and law enforcement.

This workshop is experiential training based, and uses intelligence from senior serving law enforcement officers and FCA regulators.  They will review a variety of interactive real life (sanitised) scenarios, practical exercises, short films, self-assessment exercises and in-depth typologies, which will enable them to:

  • return to their offices with the practical tools to re-examine vulnerabilities in their own business
  • make robust changes where necessary
  • ensure that they can demonstrate a thorough, holistic and highly competent approach throughout


Feedback from delegates in 2015

  • ‘Very well presented session from expert Trainer’ – Erste Group Bank
  • ‘Good interactive session. Encouraged to ask questions’ – MBNA Ltd


Recommended reading:

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Topics to be covered and objectives include*:

  • Understand your key health-checks – CEO Attestation
  • Key steps to develop a financial crime risk aware mind-set in staff
  • Making training memorable beyond the classroom
  • Health-checking transaction monitoring in the light of Stone vs. Natwest Bank – AML automated transaction monitoring in the high court – practical implications for future best practice
  • Health-check your SAR’s reporting including “lessons to be learned” – Shah vs. HSBC.
  • Health-check your enhanced due diligence and identify practical solutions when dealing with trusts, foundations and non-equivalent jurisdictions
  • Strategic health-checking your systems and processes using FCA “best practices”, identify vulnerabilities & benchmark progress
  • Strategic exercises, role plays, and practical tests to identify weak spots in the most robust systems and processes


Who should attend this workshop?

This is workshop will be of particular interest to:

  • MLROs & Deputies
  • Nominated Officers
  • Internal Auditors
  • Heads of Compliance
  • Senior Management responsible for AML/CTF & anti-financial crime
  • Non-executive Directors
  • Operational Risk Directors & Managers
  • Compliance Officers with AML/CTF/FC responsibilities

Workshop Outline*:

Session I: Keeping pace with Money Laundering & Financial Crime
Session II: Health-checking your Training and Awareness Programmes
Session III: AML Health-checking transaction monitoring and client screening systems
Session IV: Health-checking your SAR’s regime
Session V: Ongoing Customer Due Diligence Issues
Session VI: A Proportionate, Risk-based Health-check Programmes

Programme details:

Registration:  09:00
Start:  09:30
Close: 17:00
Lunch will be served and there will be two 15 minute breaks (mid-morning, mid-afternoon).


*  Please note that the programme sequence and/or subject matter may differ from what is presented herein; the programme is constantly being updated to embrace new ideas and developments – as they evolve.

Trainers use a blend of presentational methods in order to assist in a delegate’s understanding of the workshop content; where applicable and possible, the workshop is enhanced through the use of group exercises, role play, and case studies.

Paul Whittaker

Solicitor, LLb (Hons), MCSI, CFE,  Magic Bullet Associates 


Paul began his career in the early 1990’s as a Compliance Officer at the Financial Services Regulator and subsequently became the Global Head of Risk and Compliance Training for HSBC Global Private Bank.


Paul’s career has also spanned both Securities Trading (former Deputy Compliance Director holding CF10 and CF11 functions) and Banking (Senior Compliance Manager at HSBC London Private Bank).


Paul has significant experience in investigating and managing major fraud and corruption investigations and regulatory enforcement actions:

  • Paul is a qualified Solicitor and Certified Fraud Examiner.
  • He is a Chartered Member of the Chartered Institute for Securities & Investments and serves on its compliance forum committee.
  • Paul is a former appointee to HM Treasury’s Money Laundering advisory committee, and served on JMLSG’s editorial panel drafting the first radical revision of the risk-based guidance.
  • He has lectured at the BBA, CISI and APCIMS conferences, and a national investors show; area of expertise is Money Laundering best practises and regulatory topics.
  • Paul has written articles on market abuse for the Solicitors Journal and Investors Week.


In 2013 Paul established the Compliance and Risk Training Consultancy, Magic Bullet Associates. The consultancy undertakes training on behalf of BBA and the CISI and is performing a range of regulatory consulting projects on behalf of a number of global investment banks and private banks.

Take this workshop in-house

If you have five or more delegates who wish to attend this course, it may be more cost effective to run it in-company. To find out more about in-company training, please contact Philip Allen Director of Learning on 0207 216 8843 or

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