Contents

  1. Introduction to the anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy
  2. Regulatory framework – scope of policy
  3. Responsibilities
  4. Anti-money laundering
  5. Expectations
  6. Reporting fraud, bribery and corruption
  7. Client identification procedure
  8. Record keeping procedures
  9. Risk assessment, management and internal control
  10. Gifts and hospitality
  11. Proactive anti-fraud initiatives
  12. Raising concerns (whistleblowing)
  13. Annex1 – Bexley’s procedural and regulatory framework
  14. Annex2 - statutory framework
  15. Annex3 - London Borough of Bexley - code of conduct
  16. Annex4 - anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy

9. Risk assessment, management and internal control

The Council will have an up-to-date council-wide risk assessment that is unique to the Council, is in writing and can be provided on request.

The risk assessment is to incorporate the steps as set out in Regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 for identifying the risks of money laundering and terrorist financing to which its business is subject.

The risk to the Council of contravening the anti-money laundering legislation will be assessed on a periodic basis and the adequacy and effectiveness of the Anti-Money Laundering Policy, Guidance and procedures will be reviewed in light of such assessments.

The adequacy and effectiveness of, promotion of, and compliance by employees with, the documentation and procedures will also be monitored through the Council’s Corporate Governance and Anti-Fraud and Corruption Policy frameworks.