Many firms have the perception that the Middle East has a lighter touch regulatory environment than the financial markets of Europe or the US. However, when it comes to Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) this is simply not true and many foreign firms are surprised at how stringent the regulatory requirements are.
Many of the regulatory actions taken regarding AML/CTF are related to failings in systems and controls rather than actually laundering money or financing terrorism.
AML and CTF must be a key component in your Firm's operations and must be kept under constant review to ensure that you remain compliant with the regulations and that you monitor your customer base on an ongoing basis.
Your Firm must have effective preventative controls
Over the years the procedures and controls around AML have grown and now the focus is not just on AML but also on CTF. Countering Terrorist Financing is a concern not just to regulators but governments as well. Sanctions checking must very much be a part of your onboarding and screening process before providing a financial service to anyone, Corporate or Individual. Financial services firms are considered to be the gatekeepers of the financial markets and therefore undertaking adequate due diligence on all clients and reporting any suspicions is a crucial part of the regulatory environment in which we work. Ultimately the regulators want to ensure that firms are protecting the integrity of the financial markets.
Drawing on experienced AML professionals
As MLRO’s ourselves, all of our consultants are keenly aware of the regulators' focus and their requirements in relation to Customer Due Diligence (CDD) even when standard client information is not available. While regulations provide you with guidance on CDD requirements there is no “one size fits all” approach that can work. Standard templates provide a helpful guide for onboarding clients but sometimes it is expertise and experience that is required when clients simply do not or cannot tick the relevant boxes.
All financial services firms have a requirement and a responsibility to establish robust AML CTF procedures which are not only written but implemented, monitored and updated as and when necessary. Regulators themselves are also being proactive in ensuring firms have effective systems and controls for AML and CTF and are now undertaking client file reviews on a much more regular basis. CCL will help you to get it right first time so that when the regulator does come in and look at your files they can be satisfied that you have met their requirements.
At CCL not only do we bring you the expertise of the regulatory requirements, but also the experience of dealing with more difficult to verify clients, as well as our knowledge of the local markets.
Our AML consultancy services include:
- Reviewing your Firm’s AML policy, including supporting procedures
- Assessing the governance and oversight of AML in your Firm
- Reviewing your client files to ascertain the adequacy and sufficiency of your customer due diligence (CDD)
- Expert guidance regarding on-going monitoring including CDD, suspicious activity and transaction monitoring
- Providing AML training tailored to your Firm's business and regulatory requirements