1. Status, approval and review

These are the policies, controls and procedures Carrow Hale Residential LLP uses to manage the risks its firm-wide risk assessment identifies. Where the business said something is not yet in place, they say so and list it under Actions in section 10.

• The business must establish and maintain policies, controls and procedures to manage the risks identified in its risk assessment, review and update them regularly, and keep a written record of them, of any changes, and of how they were communicated within the business (reg 19(1)).
• They must be proportionate to the size and nature of the business and approved by its senior management (reg 19(2)); HMRC asks for the names of the approvers and the date to be recorded, and for the policies to be reviewed at least annually (HMRC AMLG1900).
• The same duty applies to the risks of proliferation financing (reg 19A).

AML policies, controls and procedures: The business has documented AML policies, controls and procedures. Last reviewed or completed: 1 June 2025.

MLRO report on how well the AML controls work: To be introduced (see Actions).

The firm-wide risk assessment rates the business’s overall risk as High, and its proliferation financing risk as Low.

The rest of the full document

• 2. Nominated officer, registration and internal controls
• 3. Customer due diligence, on both parties
• 4. Enhanced due diligence, PEPs and ongoing monitoring
• 5. Client money
• 6. Financial sanctions and reporting to OFSI
• 7. Suspicious activity reports
• 8. Training
• 9. Record keeping
• 10. Controls, actions and approval
• Sources