AML/CFT Compliance Support
Financial institutions and designated non-financial institutions are operating in an increasingly complex regulatory environment. More specifically in the area of anti-money laundering and terrorism financing. The regulator issued a new Handbook effective as of January 1, 2020, and regularly provides updates on its mandatory directives and guidelines, that you have to comply with.
Our AML/CFT Compliance Services include:
Business Risk Assessment
We can conduct a complete Business Risk Assessment according to the requirements in the Regulator’s Handbook 2020, effective 1 January 2020. The Business Risk Assessment will be conducted closely with the service provider where the risk appetite will be defined, the corporate structure, service, client and delivery channel risks will be classified, and at last the ML and TF risks scenarios will be described and scored based on their likelihood and impact on the service provider.
Customer Risk Assessment
The Customer Risk Assessment entails an assessment on the complete current client portfolio of the service provider based on different criteria’s such as client’s type, transaction type, relationship with non-qualified AML/CFT and sanctioned countries. Each client will be ranked in low, medium or high-risk clients.
We can conduct a gap analysis on the current AML/CFT compliance and risk management of the service provider based on the statutory and regulatory requirements of the Regulator. Based on the findings, a set of recommendations will be given to the service provider on the design of the AML/CFT Framework, including a roadmap for the implementation.
We can formulate an AML/CFT Strategy in accordance with the current Risk Management Systems within the service provider. The AML/CFT Strategy will be divided by different strategic objectives covering each risk area identified by the service provider in its Business Risk Assessment.
AML/CFT Policy and Procedures
We can design or update the AML/CFT Policy and Procedures according to the requirements in the Regulator’s Handbook 2020, effective 1 January 2020. If the service provider already has an AML/CFT Policy and Procedures in place, a (high-level or detailed) gap analysis can be executed and reported on which areas the AML/CFT Policy and Procedures needs to be adjusted for it to be compliant with the laws and regulations.
Risk Based Approach - Customer Due Diligence
We can design or update a customer onboarding and client due diligence system according to the requirements in the Regulator’s Handbook 2020, effective 1 January 2020. The update of the customer onboarding and client due diligence system involves a (high-level or detailed) gap analysis and report on which areas the customer onboarding and client due diligence need to be improved for it to be compliant with the laws and regulations.
AML/CFT Functional Monitoring
We can conduct an independent periodic policy and procedures assessment in order to identify whether the employees are complying with the required risk management and AML/CFT policy and procedures. This is a recurring service and can be conducted yearly or bi-yearly.
We can provide trainings on the AML/CFT State Ordinance and application of the requirements in the Regulator's AML/CFT Handbook 2020, or tailored AML/CFT risk awareness trainings to ensure that the employees understandhow to identify, prevent, mitigate, and report ML and TF e.g. red flags, PEP. A trainings plan can be formulated where all the trainings are customized to the service providers needs and ongoing cases. Our trainings can include an assessment of the content to the participants.
Preparation to Regulatory Inspections and Requests
We can provide guidance and help in preparation for a regulatory inspections and request by the Regulator, e.g. functional monitoring, analyze a specific request of the Regulator and advise hereof.
We can provide remedial services in case a sanction or point of attention was given by the Regulator to the service provider e.g. advise on risk management systems, risk control measures, trainings, AML/CFT Strategy and so on.