Some of the Components of Anti-money Laundering (AML) Compliance Program
In today’s world of terrorist financing risks, anti-money laundering (AML) compliance is essential to help mitigate the risk of fines for non-compliance and character damage. As much as the need for AML is open, the question would be on how to optimize a compliance program so that it’s efficient, scalable, and adaptive. This is because organizations are consistently changing as is the nature of their businesses; the risk outlook they’re dealing with, the area they function in, and the systems and processes are fairly unpredictable. Experts in the compliance business have wrapped around offering the key components of the effect AML compliance program.
Briefly, the AML compliance program is a procedure that describes how a company controls accounts, discovers and reports financial crimes to appropriate authorities. In principle, a compliance program handles the inherent and residual money laundering risks companies’ faces.
Now, an intelligent compliance program considers all these elements and is vibrant, ever-advancing, and improving, but not reactive.
What Are Some of The Anti-money Laundering (AML) Compliance Standards?
Majority of the components of compliance are not prescriptive, but rather depend on risk assessments. In retrospective, assessments require value judgments. To put into perspective and organization requires standardizing and imposing a formidable set of values to direct all staff on all anti-money laundering (AML) compliance associated decisions and actions.
Again, the executives and the board require creating clear and accurate policies that spin out to the entire organization. On the other hand, the compliance team requires resources to conduct their duties, including sufficient staff, technology, and training materials. The moment you’re having and upholding written policies and making them freely available is essential to having effective standards:
- What data are you gathering?
- What constitutes your privacy and security policies?
- Who needs access to what information?
- What constitutes your risk-alleviation policies?
- How do you tackle questionable activity?
- Who has responsibility for the program?
These, among others, demonstrate some components to consider when updating standards.
What Are Some of the Anti-money Laundering (AML) Compliance Processes and Systems?
Well, it’s one obligation having the written standards and another to have systems to execute internal control processes. Now, each policy needs a workflow to determine a step-by-step process. Customarily, the procedures were conducted manually, thus slow, cumbersome, and demanding on staff. Progressively, compelled entities have adopted digital technologies, permitting for automation of several steps, enhancing throughput, accuracy and great utilization of compliance’s time.
Creating an AML Compliance Program
Well, when developing an anti-money laundering (AML) compliance program, an institution must deliberate on certain elements such as the risks they are subjected to, anti-money laundering regulations in their area, and amalgamation of suspicious activities. One appropriate approach is through drawing solid guidelines to simplify the processes devoid of compromise.
How to Create the Program: A Short Guideline
Here is a short guideline to create this program:
Discovering of Suspicious Activities
The first step is discovering suspicious activity. How then can you do that? The thing is that you must have systems in place for prompt detection of activities related to money laundering. For instance, terrorist financing is one of the suspicious activities which include:
- Extensive intensifications in cash deposits of any person or business without obvious reason.
- Offering minimum or fabricated information when applying to open a bank account.
Following on Recommendations 20 of the FATF, if a financial institution has reasons to question those funds and the earnings of financial crime or associated to terrorist financing, it must report to the appropriate Financial Intelligence Unit (FIU).
The moment you employ risk assessment/evaluation, you stand to have a full understanding of the different tiers of risks a customer submits and how to alleviate them. You can determine the level of whether a customer is high or low-risk by gauging them with a scoring model. The scoring model must deliberate on a culmination of the risks factors including, the geographical area, PEPs, UBOs; and results of the needed KYC due to diligence procedure. Besides, the information offered by the AML regulators within the company’s jurisdiction should guide in the due diligence process.
When you talk about internal controls/regulations is about the policies designed to alleviate the risks of money laundering and promote compliance with anti-money laundering (AML) compliance regulations. And, therefore, it is the prerogative of banking institutions to put measures in place for sharing information within the organization for AML reasons. For internal controls, organizations can put in place the following steps:
- Due Diligence Vetting – Organizations should integrate their due diligence processes to include all compliance requirements to cut across customers and business partners.
- Creating roles and responsibilities about internal controls by creating an AML compliance officer and for large firms/institutions: a Money Laundering Reporting Officer (MLRO).
- Designing of the staff training program to meet the requirements of the company and must be adjusting based on changes in legislation or whenever a serious event occurs.
Anti-money Laundering (AML) Compliance Training Program
One would ask who should be trained concerning the program. And, thus, it should be a financial institutions policy to assign an advanced level of training to staff in parts prone to higher AML risks. These may include staff with direct customer contact; operational departments; compliance and audit staff; experts, and senior management.
The world is a global village now that information can travel from one digital system to another. Consequently, there is a substantial surge in the number of legislations concerning how legal entities, particularly financial institutions, to tackle financial crimes like money laundering and terrorist financing. The anti-money laundering (AML) compliance program is a policy that must be adopted by financial institutions to detect such vices within their accounting transactions. For a better world, such programs are essential in combatting some of the heinous crimes committed worldwide.