For many smaller firms, it is not possible to achieve the requirement of independence where the person conducting the test cannot perform or be supervised by any person who performs any of the tasks to administer the AML program. Larger firms either require or prefer to have a third party to perform the test of this critical function. Compliance Advisers has developed a comprehensive, proven testing model through which our staff conducts an independent, objective examination of a firm’s anti-money laundering compliance program which can be done onsite or remotely. Testing consists of both quantitative and qualitative testing methods that address the following areas:
Risk Assessment – does the firm conduct a risk assessment of its AML program; and if so are the risks identified addressed in the written procedures?
Written Procedures – test to determine if the written procedures of the firm are up to current standard. AML procedures seem to change every year and firms are expected to remain abreast of the changes and implement new procedures as required.
Customer Identification Program (CIP) – test to determine if the firm has the critical components to identify customers on account opening and to perform maintenance review of customers. Does the CIP provide procedures based on risk of client and account types?
Suspicious Person Review – test to ensure the firm has adequate procedures to review suspicious persons lists; test to insure that the firm responds to FinCEN requests.
Suspicious Transactions and Activity Reporting – test customer files to determine if CIP is fully and meticulously implemented, determine if the firm has certain customers that present more AML risk. Tests on transactions to look for activity that displays characteristics of money laundering; test to ensure that the firm follows up on any activity identified as suspicious; test to determine if the firm has adequate SAR reporting procedures.
Notice to Customers – test to determine if the required disclosures are made to customers regarding the firm’s AML program.
AML Training – test to determine if the firm conducts AML training that is customized to the firm’s specific operations.
AML Testing – has the firm maintained a consistent AML testing program and has the firm corrected any deficiencies highlighted by testing; has senior management signed off on the AML test and the AML program?
Test results are provided to the Firm in a Comprehensive Report of Findings and Recommendations to ensure compliance with applicable AML Rules, the details of which are discussed with Firm management.
But we don’t stop there. We work with you until the Firm has addressed all noted deficiencies, after which a Final AML Certification Certificate is issued to the Firm to complete the testing process.