ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM (AML/CFT) HEALTH CHECK
Since 2008, banks have paid over USD$261 billion in fines for non-compliance with financial crime laws. Many AML/CFT Programs are falling way short of what regulators expect of them, allowing organised crime to launder trillions of dollars a year through the world economy. We built the AML/CFT Health Check to help regulated entities assess the effectiveness of their AML/CFT Programs and identify, track and manage, deficiencies which could expose them to significant financial, regulatory and reputational risk.
There are now over 200 Financial Action Task Force (FATF) member countries that are subject to mutual evaluations to assess the effectiveness of each countries AML/CFT legal and regulatory framework. Globally, AML/CFT legislations applies to millions of organisations, of different shapes and sizes, across a diverse range of financial and non-financial sectors, requiring them to comply with a complex and ever changing set of AML/CFT compliance requirements.
What is the AML/CFT Health Check?
The AML/CFT Health Check solution is an online platform dedicated to controls assurance and provides a structured framework for conducting independent reviews to assess the design and operational effectiveness of anti-money laundering and counter-terrorism financing programmes.
The AML/CFT Health Check platform has been designed to leverage best practices in risk management controls assurance and was built based on a logical hierarchy that links rules and obligations, with policies, risks and controls and provides a means of assessing compliance against obligations, prioritising responses, providing auditor comments and management responses, as well as, assigning actions and attaching documentary evidence to support audit findings.
After the assessment has been completed for each compliance obligation users can create executive summary reports directly from the platform, highlighting the key observations, findings and recommendations, as well as, actions, issues and risks identified during the review process.
The AML/CFT Health Check platform also contains rich data analytics that provide actionable business intelligence including; real-time operational dashboards for tracking open and outstanding actions, issues and risks; interactive reports which can slice and dice audit data in many ways including, drilling into particular areas of interest, as well as, benchmarking audit outcomes across different timeframes, divisions and countries, it can even summarise on a single page the compliance status across hundreds of compliance obligations.
Financial crimes are occurring 24/7, 365 days a year and costs the world economy trillions of dollars. Anti-money laundering and counter-terrorism financing laws now apply to millions of organisation’s of all sizes, across a range of industry sectors and over 200 member countries of the Financial Action Task Force.
The stakes have never been higher for regulated entities to demonstrate to Boards and regulatory authorities that they have an effectively designed, implemented and maintained AML/CFT program and it is a mandatory requirement that these are subject to regular independent review.
The independent review process can be a time consuming and expensive exercise and often fails to deliver clear insights into compliance gaps or provide actionable business intelligence needed to make improvements to AML programs, with one-dimensional report outputs being of limited value to the organisation after the consultants have left for the next job.
Regulated entities need to have a robust framework for regularly monitoring the effectiveness of the AML/CFT compliance programme to assess whether it is adequate and proportionate; meaning, whether systems, procedures and controls have been designed in a way that are fit for purpose and have been implemented and are operating effectively.
The outputs of the AML/CFT programme review need to be provided back to top management and a commitment made for tracking and implementing continual improvement to address any compliance gaps identified if the organisation is to avoid material fines and penalties for non-compliance which for the global banking community alone has exceeded USD$260 billion, in less than a decade.