An Illustration of an Internal AML Audit Process

Illustration of a General AML Audit Process

An illustration of the general process:

Stage 1: Pre-onboarding process

All clients are subject to client due diligence (CDD). This takes the form of questionnaires, e-verification checks, certified documents, open banking and any further checks or inquiries.

All pre-onboarding CDD inquiries have to be concluded, before the Initial Meeting and Audit Plan.

Stage 2: Initial Meeting and Audit Plan

At this appointment, we will ascertain what your needs are, agree what is to be included in the Audit Plan, such what type of audit you seek, and the documents that we will request from you.

During this appointment we will also check original documents such as passports for likeness.

Stage 3: Documentation

We send you the Audit Plan for your Approval, inform you of the documents we will require, send the usual onboarding documents, details of the fixed fee plus VAT, and payment details.

Stage 4: Documentation

You provide the documents requested.

Stage 5: Interviews

We attend the firm and interview various staff members.

Stage 6: AML File Reviews

We attend your firm and conduct the AML File Reviews.

Throughout the stages we will liaise with your MLRO.

Stage 7: Draft Report

We will prepare a draft report, speak to the MLRO/Board, and seek your responses

Stage 8: Finalise the report and send it to the MLRO/Board

Stage 9: Implementation Follow-Up Report

If you require an Implementation Follow Up Report, this can be arranged. This is usually done 3 months after the Audit.

The above is an example of an audit process, the actual process in respect of your firm might differ completely.

Payment of Fees in Advance

Different stages of the process are subject to separate fixed fees plus VAT. VAT is charged at 20%. All fixed fees and VAT, CDD Admin fees and VAT(VAT is 20%), are to be paid and cleared before any work is undertaken. Thus you will need to pay for the Initial Meeting and Audit Plan and the CDD Admin fee and VAT prior to the Initial Meeting and Audit Plan, and you will need to pay for the agreed audit work and VAT before the work is undertaken etc.

Exclusion from the Audit Function:

It is not within the scope of the Audit function to provide advice on the Money Laundering Regime, Sanctions Regime, or any other regulatory matters. Therefore, we do not offer advice on legislation or regulatory compliance, nor do we act as legal representatives. The recommendations made during an audit are not to be construed as advice.

Your firm is responsible for ensuring compliance with all relevant legislation and regulatory guidance. This includes the preparation of Firm Wide Risk Assessments, Client and/or Matter Risk Assessments, as well as the development of Policies, Controls, and Procedures. If your firm requires assistance with these tasks, were commend seeking the services of a specialised firm or consultancy before engaging in an audit. Please be aware that our role is strictly limited to conducting audits and providing recommendations based on our findings. It is important for your firm to take ownership of its compliance obligations and seek appropriate guidance when needed.]


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