We will work with your Compliance Team to tailor the software to meet your unique risk profile and agree a training and implementation plan.
What is it?
The new 2017 Money Laundering Regulations set out “What” regulated persons are required to do to be Compliant.
The JMLSG Guidance, Law Society Practice Note, HMRC AML Guidance and FATF are all excellent at explaining and expanding on the “What” regulated firms are required to do.
The AML Compliance Solution is a simple and flexible software framework that helps firms with “How” to embed Money Laundering compliance in all regulated work done by the firm.
We are working on enhancements to handle the changes introduced by the new 2017 Money Laundering Regulations that will come into force on 24th June this year and the career-ending penalties for a Sanctions breach introduced by the Policing and Crime Act 2017 on 1st April this year.
What do you need to do to make it work for you?
A key element in the success of each installation is the wholehearted commitment and backing of the Management Board. This must to be communicated clearly to all staff and enforced with carrots and sticks.
We work with your AML Board member, MLRO (Money Laundering Reporting Office) and Compliance Team to tailor the policies, controls and procedures built into the software to fit the way your firm works.
Your Compliance Team, when they feel they are confident and competent in both their skills in using the system and their knowledge of the AML principles that underpin it, roll out the system to the rest of the firm.
When the system has been rolled out your Compliance Team assumes day to day responsibility for ensuring everyone performs their assigned role(s). We step into the background, but are always available to help and support your AML Board member, MLRO and Compliance Team.
If your Management Board is committed to embedding a culture of Anti-Money Laundering Compliance we can help you make it happen. Every regulated firm is different but the AML Compliance Solution is flexible enough to work for most.
The quickest way to get a feel for whether the AML Compliance Solution will work for your firm is to book an online Guided Tour for you and the others within your firm who will be involved in the project.
An overview of the “How”
The first training session we have with a firm’s AML Board member, MLRO and Compliance Team centres on the 8 Pillars of Money Laundering Compliance.
The 8 Pillars summarise on one A4 page what firms have to do to be Compliant. We run through a GAP analysis identifying areas where the firm is doing well and where it would like to do better.
We look at how each of the 8 Pillars is covered within the AML Compliance Solution and discuss the Money Laundering requirements that have driven the design of the tools provided. We also look at areas where tailoring is required to fit how the firm want to work and where the firm might adjust its existing practices to take advantage of certain facilities.
There follows a brief overview of the 8 Pillars of Anti-Money Laundering Compliance with an indication of the principal actors including a short video covering some of the bulleted points.
If there are particular areas that interest you, please let us know when booking your online Guided Tour and we will explore these with you in more detail.
- Crafted to address AML/CTF risks faced by firm.
- Take into account higher level risk assessments.
- Approved by Management Board.
- Versioning control. Record reasons for changes.
- Sanctions Check every Client & non-Client.
- FATF + other High Risk countries - Screen all clients.
- PEP check every Client. Assign risk level to any PEP.
- Import Companies House data & documents.
- Equifax ID check all/selected Clients.
- Use Acceptable ID for Individuals and Entities.
- Run Equifax ID check on every Client?
- Capture documents or knowledge used as ID.
- Shaped by Firm’s Risk Assessment. Identify Red Flags.
- Record reasoning, escalation & actions. SARs.
- New Matter - does it fit Client’s known profile?
- Changes to Client or Matter during transaction.
- Pre-Completion Review before deal with funds.
- Use AML Dashboard to monitor all Client/Matters.
- Preserve record of monitoring, actions, SARs etc.
- Report to Management Board.
- Personal Training plan tailored for each role.
- Monitor and Record who has done what training.
- Assess effectiveness of training.
- Auditor’s Mantra “If it is not recorded, it did not happen”.