Business-wide Risk Assessment
Business-wide Risk Assessment
Performing an Anti-Money Laundering (AML) risk assessment involves identifying and evaluating the potential risks and vulnerabilities related to money laundering activities within an organization.
AML-CFT Law Article 16.1; AML-CFT Decision Article 4., provide that DNFBPs may utilize a risk based approach with respect to the identification and assessment of ML/FT risks.
DNFBPs are obliged to assess and to understand the ML/FT risks to which they are exposed, and how they may be affected by those risks. Specifically, the AML-CFT Law provides that they shall continuously assess, document, and update such assessment based on the various risk factors established in the Implementing Regulation of the Decree-Law and maintain a risk identification and assessment analysis with its supporting data to be provided to the Supervisory Authority upon request.
We offer Risk Assessment services that involve:
- Identification of AML Risk Factors: Understanding the organization’s operations, your customers, products and services. It will also include Identification of specific risk factors associated with the organization’s industry, clientele, geographic location and regulatory environment.
- Assessment of Risk Exposure: Evaluation of the likelihood and potential impact of money laundering activities occurring within the organization by considering factors such as customer profiles, transaction volumes, complexity and geographic risks. It will also include analyses of adequacy of the organization’s internal controls, policies and procedures to detect and prevent money laundering.
- Know Your Customer (KYC) Controls: evaluation of the organization’s KYC procedures and processes for verifying the identity of customers. Assessment of the effectiveness of risk-based customer due diligence measures. It will also include consideration of the organization’s ability to obtain and maintain accurate and up-to-date customer information.
- Customer Due Diligence (CDD): Evaluation the effectiveness of the organization’s customer identification and verification procedures. Assessment of the risk of dealing with high-risk
customers, such as politically exposed persons (PEPs), high-net-worth individuals (HNWIs), or customers from high-risk jurisdictions. It will also include consideration of the organization’s processes for ongoing monitoring and updating customer information. - Transaction Monitoring: Evaluation of the organization's transaction monitoring system to detect suspicious transactions. Assessment of the adequacy of thresholds, rules and parameters used in the monitoring system. It will also include consideration of the organization’s ability to identify complex transaction patterns, unusual activity, or red flags that may indicate money laundering.
- Internal Controls and Policies: Assessment of the adequacy and effectiveness of the organization’s AML policies, procedures and internal controls. Evaluation of the organization’s risk management framework and governance structure. It will also include consideration of the organization’s training and awareness programs to ensure employees understand their AML obligations.
- Compliance with Regulatory Requirements: Evaluation of the organization’s compliance with relevant AML laws, regulations, and guidelines. Assessment of the organization’s ability to report suspicious transactions to the appropriate regulatory authorities. It will also include consideration of any penalties or enforcement actions faced by the organization in the past related to AML non-compliance.
- Risk Mitigation Strategies: Development of risk mitigation strategies and controls to address identified AML risks. Consideration of implementing enhanced due diligence measures for high-risk customers or transactions. It will also include implementation of a robust compliance program that includes regular monitoring, audits, and reporting.
- Documentation and Recordkeeping: Assessment of the organization’s recordkeeping policies and procedures for AML-related documents. Evaluation of the adequacy of documentation to evidence compliance efforts. It will also include consideration of the organization’s ability to provide information and records to regulatory authorities when required.
- Ongoing Monitoring and Review: Establishment of a process for ongoing monitoring and review of AML risks. Regularly reassessment and updation of the risk assessment based on changes in the organization’s operations or the regulatory environment. It will also include periodic independent audits or assessments to validate the effectiveness of AML controls.
It’s important to note that the above steps are general guidelines, and the specific risk assessment process may vary depending on the organization’s size, nature of business and jurisdictional requirements. Please contact us for further information on aml@aml360.io