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Anti-Money Laundering & Financial Crime Prevention
Lesson 6: Your Role & Responsibilities
Role-specific duties, consequences, and the final assessment
Introduction
A Bank is Only as Strong as Its People
  • Every role, every function, every individual plays a part
  • This final lesson is about you
First Line
The Relationship Manager
  • Opens new accounts, verifies identity, assesses risk
  • The first line of defence
  • In Stunt & Co: insufficient checks allowed £46.8M to flow through
First Line
Operations and Transaction Monitoring
  • Monitoring systems flag anomalies
  • Analysts triage alerts — separating false positives from genuine concerns
  • When these systems failed, the cost was tens of millions
Second Line
The Compliance Function
  • Develops policy and provides oversight
  • Manages the SAR process
  • Trains the workforce
  • Bridges front-line activity and regulatory expectation
Second Line
The MLRO
  • Every internal report passes through them
  • Evaluates evidence, decides whether to file with the NCA
  • Maintains records for at least five years
Senior Management
Setting the Tone from the Top
  • Under SM&CR, designated individuals are personally accountable
  • January 2025: financial crime elevated to a principal risk
  • A direct response to enforcement action
Third Line
Internal Audit
  • Provides independent assurance
  • Tests controls, checks policy compliance
  • Reports directly to the Board
Consequences
When Defences Fail
£42M
FCA combined fine — Stunt & Co + WealthTek
Personal Consequences
Criminal Penalties Apply to You
14 yrs
principal offences
5 yrs
failure to disclose
2 yrs
tipping off
  • These are not corporate penalties — they apply to you personally
Regulatory Direction
FCA Direction from 2026
  • AML deficiencies treated as governance failings
  • Individual Senior Managers face personal regulatory action
Course Recap
Six Lessons Complete
  • Mechanics of money laundering
  • Regulatory framework
  • Customer due diligence
  • Red flags, reporting, and your personal role
Continuing Development
Your Learning Does Not End Here
  • Annual refresher training is mandatory
  • ACAMS certification — the global gold standard
  • Recognised by regulators worldwide
Call to Action
It Starts with One Person
  • Every SAR starts with one person noticing something
  • Every prevented crime starts with one person acting
  • That person could be you
Course Complete
AML Training Complete
  • Stay vigilant
  • Stay informed
  • Stay compliant
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