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An AML reality check

Richard Simms
Richard Simms

Director and Founder of AMLCC and AMLCC Consult

A (AML) reality check

The reality is that, if you’re only collecting ID from your clients and using digital checks to verify them, you wouldn’t pass an AML inspection today.

You’re not alone. Recent statistics suggest that many firms couldn’t.

Accountancy supervisors have reported varying successes in the sector, from 26% of those inspected needing follow-up action to only between 3 and 4% of those inspected deemed to be ‘compliant’.

With huge penalties and reputational damage at stake, you can’t afford to drop the ball on AML compliance. 

If you’re already using an online AML solution that checks your clients’ identity and data, it’s a good start. But there’s more to do.

These are the five things your AML provider should be offering to keep you fully compliant:

1. Training on all areas of AML

All employees who work with clients, handle client onboarding, transactions or record keeping need to fully understand AML as a whole, not just the product they’re using, including:

bullet iconyour sector’s and business’ risks.
your business’ AML policies, controls and procedures (PCPs).
when and how to make a suspicious activity report (SAR).

Ongoing refresher training needs to be annual (at least), to keep their knowledge current. You also need detailed records of all training completed, including assessment results.

2. AML documentation

The AML documents you create must be suitable to your firm. You must mould and flex any template structures used and keep them in an easily adjustable and distributable format along with a full audit trail of changes.

bullet iconAML PCPs
Business-wide risk assessment
Risk assessments for AML-regulated services and departments

These documents must be tailored to the risks presented by the services you offer, markets you works in and clients you work with. Update all these documents annually or when the situation changes.

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3. Client Due Diligence (CDD)

This is where your ID checks come in. But that’s not all for CDD. You also need the tools to:

bullet iconunderstand the nature of each client’s business and assess the risk they present.
bullet iconknow the ultimate beneficial owner (UBO).
implement identity verification procedures.
screen against PEP and sanctions lists.

Your business must collect this information before starting work with a client. Even if it’s an existing client embarking on a new transaction with you.

4. Records of all your AML

Your records are your proof of AML compliance. You need to be able to create and store copies of:

bullet iconall AML-related documents
bullet iconall AML-related decisions you make
all client related documents
all internal and external suspicious activity reports (SARs)

If your supervisor or law enforcement come knocking, they’ll expect to see written evidence of all your AML activities.

5. Regular updates

All your AML needs to be kept up-to-date, so you’re aligned with current laws and best practices. Any provider should prompt you to regularly review and update:

bullet iconAML training
bullet iconAML PCPs
Business and client risk assessments
CDD

The AMLCC platform provides your business with all the necessary tools to everything above, and more. Allowing it to stay up to date with its AML and comply with the regulations.

The one-stop AML solution

We know AML

We’re internationally recognised AML experts
We work with most accountancy supervisors and the Law Society
Bespoke AML consultancy available for all sectors

The one-stop AML solution

We know AML

We’re internationally recognised AML experts
We work with most accountancy supervisors and the Law Society
Bespoke AML consultancy available for all sectors

What others have said

“We had the man from the ICAEW here yesterday to carry out a QAD practice review. We got a clean bill of health – not a single action point…That is in no small measure due to AMLCC so I just wanted to say ‘thank you’”

“Thank you for such a perfect and informative [solution]. You have given me a clear direction for my AML training and CPD.”

“I just wanted to say ‘thank you’ to you, Richard, and all the team at AMLCC for providing a service that really does minimise the burden of AML compliance.”

“What a refreshing pleasure working with a company who actually listens to the feedback from their customers and communicates with them!”

“Your team they have been excellent from the moment Fiona did a demo for me with only 15 minutes notice, and thoroughly going through the AMLCC product, answering the many questions I had! It was at this point at which I made up my mind this is the sort of business I want to work with for my AML.”

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