07 February 2018 
Matt Sisson, Projects and Membership Manager
2017 was a year of significant change for financial legislation and regulation. There was an update to money laundering legislation (MLR 2017), which enhanced regulation in areas such as documented risk assessments, controls and procedures. A second update was the introduction of a new Criminal Finances Act (CFA 2017), which makes companies and organisations including universities criminally liable if they fail to take measures to prevent the facilitation of tax evasion by an ‘associated person’.
We’ve produced sample policy frameworks for both Anti-Money Laundering (AML) and the Criminal Finance Act (CFA), which we hope will be useful for universities implementing responses to the legislation. We’ve put them both in the same document, so that you have the option to manage policies and procedures for both pieces of legislation in combination, or separately as required.
We refer to these as ‘frameworks’ as they’re not just sample policies - they contain both background information and relevant policy wording that you may wish to include in your own policies. You can download the document, along with other documents in the counter-fraud toolkit, here. The original Anti-Money Laundering sample policy in the Toolkit is no longer relevant, and has been removed.
The document has been prepared for us by Keith Read, who works with BUFDG and universities in the sector in training and compliance. If you have any comments or feedback, contact Matt.
