“ the challenge today is not the absence of standards. The challenge today is implementation, implementation, implementation – in short, effective and efficient action by the public and private sectors acting in partnership to stop money laundering; to reduce the harm caused by crime and terrorism.” – David Lewis, former Executive Secretary of the Financial Action Task Force (FATF)
This Keynote speech by David Lewis, FATF Former Executive Secretary was delivered at the 7th International Anti-Money Laundering and Compliance Conference:
'Fighting Financial Crime'
Bratislava, 10-11 December 2019
Independent Internal Audit
Regulation 21(1)(c): Enhancing AML Compliance Through Independent Assessment
Regulation 21(1)(c) of the Money Laundering Regulations mandates that, where appropriate to your business's size and nature, you establish an independent audit function.
This isn't merely a procedural formality; it's a strategic imperative for safeguarding your business and maintaining regulatory integrity.
Why Choose an Independent Consultant Auditor?
- Unbiased Perspective: Internal audits, while valuable, can lack the objectivity necessary to identify subtle vulnerabilities. An external consultant auditor, like us, provides a fresh, unbiased assessment, free from internal biases and preconceived notions.
- Proactive Risk Mitigation: Achieving genuine objectivity in AML audits requires more than internal checks. An independent audit eliminates the influence of internal factors, ensuring unbiased recommendations and driving continuous compliance improvement. Are internal limitations holding you back?
- Actionable recommendations: We provide actionable recommendations to help you strengthen your AML framework.
- Is "good enough" truly sufficient for your AML programme? Relying solely on documented policies without objective review can lead to unintended complacency. This approach may overlook valuable opportunities for improvement and could suggest a lack of robust governance. By moving beyond a simple "tick-box" mentality, you can proactively identify and address potential weaknesses, ensuring a more effective and resilient AML framework.
- Enhanced Regulatory Confidence: Demonstrating a commitment to independent scrutiny reassures regulators that you take your AML obligations seriously. This can be particularly crucial during regulatory inspections or investigations.
- Focus on Improvement: Regulation 21(1)(c)(ii) and (iii) require recommendations and monitoring of compliance. Independent consultants provide clear, actionable recommendations and can then monitor the implementation of those recommendations.
Schedule a consultation today to explore how objective reviews can enhance your continuous improvement efforts and strengthen your compliance.
36 Pillars of AML Compliance: Building a Robust Programme in Your Legal Practice
LSAG 23 - 36 High Principles
The Legal Sector Affinity Group's 2023 Guidance, specifically Chapter 3, outlines 36 High-Level Compliance Principles, essentially a comprehensive blueprint for building a strong Anti-Money Laundering (AML) program within your legal practice.
These principles, when implemented effectively, serve as the "building blocks" for robust AML policies, controls, and procedures (PCPs).
Key Takeaways:
- Governance is Paramount: Strong AML governance is crucial, including approved beneficial owners, designated MLRO and MLCO roles, documented responsibilities, and board-level oversight.
- Risk Assessment is Foundational: Practice-wide and client/matter-level risk assessments are mandatory, informing all AML PCPs.
- Comprehensive Policies and Procedures: Clearly documented PCPs are essential, covering client due diligence (CDD), enhanced due diligence (EDD), suspicious activity reporting (SARs), technology adoption, and staff training.
- Technology and Training: Ensure your practice adapts to technological advancements and maintains thorough, up-to-date AML training for all staff.
- Independent Audit: Where appropriate, conduct independent audits to evaluate the effectiveness of your AML program.
- Record Keeping: Maintain meticulous records for all AML-related activities.
In essence, these 36 principles emphasise a risk-based approach, requiring legal practices to proactively identify, assess, and mitigate money laundering and terrorist financing risks.
Don't leave it to chance. Contact us today for a consultation to discuss how we can help you implement and maintain a robust AML program aligned with these critical principles.
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