It’s tempting at this time of year to pack away the AML/CFT Risk Assessment and Programme, and think:
”I’ll come back to this when I next have to”.
Now that your independent audit is complete, you’ve submitted your Annual Report to your supervisor, and you know there is at least four months until you have to undertake the next internal audit, it’s tempting to just put your anti-money laundering compliance programme on the backburner for a bit.
During this quiet period in between reviews and reporting, is there one small, incremental improvement you can make to your anti-money laundering compliance regime? The sort of improvement that doesn’t feel important enough to focus on during the large projects? Here are some ideas of small improvements that are easy to implement and that could have lasting positive effects:
- An improved governance reporting paragraph: is your board getting the right compliance information in their monthly reports?
- A refreshed AML/CFT Training Log: you might be capturing which of your staff are attending training and when, but are you adequately describing the content of the training so that you know which areas may need to be the focus of future training?
- Was there a “minor” finding in your independent audit that didn’t seem like it required immediate remediation at the time, but that you still need to get around to addressing?
- Getting clear on the difference between verifying the “source of funds” and the “source of wealth” in your enhanced due diligence programme? How does your high risk customers require both or either of these?
- Investigating electronic transaction monitoring or customer identification processes: could you be preparing a business case for senior management to consider during your next budget round?
Small, ongoing improvements to your anti-money laundering compliance programme can prevent the project feeling overwhelming and demonstrates your commitment to your supervisor that they do not need to pay close attention to your progress.
Want some help or advice? Be in touch with Fiducia for a friendly and free chat about your ongoing compliance improvements on email@example.com or +64 21 256 1641.