MLR1PP3100 - Penalties guidance: anti money laundering/counter terrorist financing legislation: civil penalties

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017:

• Regulation 76(2) says penalties must be appropriate. This is defined as effective, proportionate and dissuasive.
• Regulation 76(4) says that we must not impose a penalty where there are reasonable grounds to be satisfied that the person took all reasonable steps and exercised all due diligence to ensure the requirements would be complied with

Schedule 7 Counter Terrorism Act 2008 (CT Act):

• Para 25(1) says penalties must be appropriate. This is defined as effective, proportionate and dissuasive
• Para 25 (2) says that we must not impose a penalty where there are reasonable grounds to be satisfied that the person exercised all due diligence, and took all reasonable steps to ensure the requirements would be complied with.