Using an AML review to protect your Firm
Failure to implement effective Anti-Money Laundering (AML) controls in your Firm will leave you vulnerable to fines, criminal proceedings and crippling reputational damage.
Proactive action to assess and test your AML framework can help you avoid these potential impacts.
An AML Review includes a detailed review of your AML Policies and Procedures, which includes:
- A review of your AML manual
- Client onboarding procedures and KYC responsibility allocation
- AML Business Risk Assessment
- Customer Risk Assessment procedures
- Ongoing due diligence procedures
- Suspicious activity reporting
We will also review:
- the processes in place for transaction monitoring, ongoing sanctions compliance, identifying and reporting suspicious activities and any IT solutions in place to deliver these requirements
- internal governance arrangements around the AML framework, including internal reporting, escalation processes and dispute resolution
- the training needs analysis process and corresponding training programme in place
- a representative sample of Client files across all types of business, geographies and financial services provided, concentrating on those Clients that present the most risk
We will work with you to prioritise the specific activities that must be carried out in order to remediate any weaknesses identified from our review of your AML framework and Client files.
These tasks will be risk-based, time-bound, and assigned an appropriate owner.