AML
Overview
An anti-money-laundering framework is judged on what can be evidenced, not on what the manual says. The two are often further apart than a firm expects.
We build and review AML and counter-terrorist-financing frameworks for credit and financial institutions and for the non-financial businesses that fall within the same regime: the risk assessment, the policies that sit beneath it, and the controls that put them into practice.
We also act when a framework is examined. That means preparing for a supervisory inspection, assembling what is asked for, answering the findings and running the remediation afterwards. Between inspections, we support the compliance officer on the decisions that arrive weekly rather than annually.
What we advise on
Drafting and reviewing the policy set and the control framework beneath it, so the documents describe what this business actually does rather than a generic programme carried over from somewhere else.
Designing the customer risk assessment and the due diligence that follows from it, including enhanced measures for higher-risk relationships and the evidence each decision leaves behind.
Screening arrangements for customers, counterparties and transactions, how matches are handled, and the internal procedure for a relationship that becomes subject to restrictive measures after it has been opened.
Preparing for an on-site or thematic inspection, assembling the file the supervisor asks for, responding to findings, and planning and running the remediation that follows them.
Role-specific training for boards, compliance teams and front-line staff, and standing support for the compliance officer on the questions that arrive between formal reviews.
The internal escalation path from an alert to a decision, the preparation of reports, and the handling of requests and follow-up correspondence from the Financial Intelligence Service.
Compliance framework
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Obliged entity
A business or profession to which the anti-money-laundering regime applies. The category covers credit institutions and financial institutions, and professionals such as auditors, accountants, tax advisors and notaries acting in their professional capacity.
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Beneficial owner
The natural person who ultimately owns or controls the customer, or on whose behalf a transaction or activity is being conducted.
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Politically exposed person
A natural person who is, or has been, entrusted with prominent public functions - among them heads of state and government, ministers, members of parliament, and members of supreme and constitutional courts.
Discuss your framework with our team.
Tell us where your framework stands and we will set out what a review would cover.