AML: a fundamental focus
Compliance with AML regulations should be a fundamental area of focus for your Firm. Regulators levy severe penalties on firms whose weak systems and controls lead to inadequate protection against money laundering. In addition to any fine you may incur, your Firm’s failings will become public, and the reputational damage could be irreversible. The key to AML compliance is effective Customer Due Diligence (CDD) and robust AML systems and controls. Your client onboarding procedures are vital to mitigate the associated risk of AML failings.
Protecting your Firm with a full AML review
We can help your Firm to manage this risk by conducting an AML Review of your Firm’s systems and controls. Our AML reviews include:
- A detailed review of your AML policies and procedures such as your AML manual, client onboarding procedures and sanctions compliance, KYC responsibility allocation, your AML business risk assessment and your customer risk assessment procedures
- A representative sample of your client files, concentrating on the clients that present the greatest risk
- A review of your internal governance arrangements around your AML framework, including suspicious activity reporting, escalation processes, and dispute resolution
- A review of your training needs analysis process and corresponding training programme established
- An assessment of the criteria you use for transaction monitoring and the process you have implemented for flagging transactions that fall outside of the customer’s profile
- A review of your MLRO reports, including any annual returns
We will then work with you to define the specific actions that must be carried out to remediate each of the weaknesses identified within your AML framework and client files. Following a period of ongoing monitoring to assess the implementation of the remediation plan, we will produce a report on the output of the AML review for your compliance function and your senior management team.
Take a proactive approach to protecting your Firm
For a specific discussion on the application of our AML review for your Firm and assurance that your AML framework is current, effective and compliant, contact our experienced AML consultants.