AML quick links
AML COMPLIANCE TOPICS LINKS
System & Controls
“How effectively does the business manage systems and controls to ensure AML compliance?”
Systems & Control
The following are required:
• assess client risk
• perform CDD
• monitor client risk
• maintain appropriate records.
Additional systems may be necessary:
• screen staff
• business continuity
• review practice
• SAR reports
- A comprehensive ‘Firm Risk Assessment’
- A policy statement which demonstrates engagement; owned by the responsible member and tailored to that business, setting out the procedures and controls that will be used in practice.
- Sufficient and relevant written procedures which explain the detailed actions that will be carried out (for example information gathering and risk assessment in relation to dealing with a new client OR How SAR reports are instigated and progressed)
- Methods of working and oversight which ensure consistency and adherence to practice procedures.
- Effective and updated training for AML and SAR reporting
- Checks and measures to ensure integrity of employed staff and performance in relation to contracted services being provided to, or by, the practice.