Recent AML Work
S.166 review focusing on AML systems and controls at a large European Bank
The scope of the review covered the bank’s systems, procedures and controls around governance, risk assessment, enhanced due diligence, PEPs, ongoing monitoring, sanctions screening, transaction monitoring and suspicious activity reporting.
Global bank with international wealth management division
The scope of the review covered bank’s AML and CTF systems and controls with specific areas of focus lead by the client. We undertook a detailed review of how the AML and CTF risks were identified, assessed, mitigated, managed and monitored within the bank and provided a comprehensive gap analysis with a detailed list of recommendations.
As part of this review, a substantial sample of client structures was selected to ascertain the quality of controls, KYC procedures and governance arrangements for the client files over a period of time.
Harmonization of AML policies, procedures and systems such that all bank branches adhere to the same regulatory approach.
Comprehensive on-site review of existing AML arrangements resulting in a gap analysis against current regulatory requirements and industry best practice; implementation of AML anti-bribery policies and procedures, with the successful adoption of an interim manual monitoring processes while awaiting the approval of an electronic solution by head office.
Investment bank in Hong Kong
Assessed the adequacy of the bank’s internal controls, systems and procedures in respect of account opening and KYC procedures, book-building, underwriting and sponsorship work, and its compliance with applicable legal and regulatory requirements.
Trust division of an international bank in Jersey
We were appointed to provide an Article 32 report to review the governance, regulatory and AML arrangements for the trust company business of an international bank with operations in Jersey. The work entailed a review of governance arrangements, effectiveness of internal policies and procedures and the administration of a sample of 50 client relationships.
We conducted a gap analysis against the regulatory framework and made recommendations for improvement.