AML Policies and Procedures – Top Tips for a Successful AML Review

Top Tips for a Successful AML Review

1. Define the Goals & Objectives of the Review

Remember that the main goal of a review is to identity any potential weaknesses within your current AML controls in order to ensure your efforts are as robust as possible.

2. Collect Relevant Documentation of your Firms current AML efforts

Relevant documentation may include (but not limited to)

• Your firms AML policy which stipulates your organisations internal AML/CTF procedures – for example your firm’s policy in relation to the disclosure of suspicious activity
• Documentation which shows a record of staff AML training
• Evidence of your firms’ risk-based approach and customer risk assessment procedures
• Evidence of onboarding due diligence and ongoing due diligence procedures
• Your firms risk assessment

3. Assess and Test

Assess your current efforts and ask key questions such as;

• Does staff receive regular training? Is the AML training program you subscribe to up to date with the evolving AML legislation?
• Are findings dealt with in a timely and efficient manner? Is there a backlog in suspicious activity reporting?
• Is the risk assessment thorough? Is it tailored to your business and outlines accurately your unique risk exposure?
• How effective and robust is your AML systems? Are they adequately in line with the latest AML legislation?
• Are your due diligence practices appropriate? Have you distinguished an appropriate procedure for higher risk clients? How effective is your ongoing monitoring and screening of higher-risk customers?

4. Recommendations

Clearly report your findings and make clear, measurable recommendations to improve your internal aml policies, control and procedures.

With these recommendations, create an actionable plan to tackle the deficiencies found.