The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended) (referred to as the 2017 MLRs hereafter), sets out in Regulation 21 details of internal controls.
Section (1) (b) states that a relevant person must carry out screening of relevant employees appointed by the relevant person, both before the appointment is made and during the course of the appointment. Section (2) explains that “screening” means an assessment of:
the skills, knowledge and expertise