It has often been said that the first step to solving a problem is admitting you have a problem. In the world of AML Audits, that begins with evaluating the risk of AML violations. Today we are going to look at some areas that all compliance officers should ask themselves about before they begin a formal risk assessment.
- Is there a culture of compliance?
- Are the board and senior management involved in the oversight and management of compliance risk?
- Do employees receive regular and timely communications and training on AML issues and the financial institution’s own internal policies and procedures?
- Are there periodic monitoring programs in place to ensure achievement of compliance goals and objectives?
- Are policies and procedures in place across the organization to detect and deter unusual activity such as money laundering?
- Is there a well-functioning whistleblower program?
- Are clear escalation processes in place to respond to weaknesses or unusual transactions that are identified?
- Is there compliance planning and monitoring?
- Does the AML compliance team have the requisite subject-matter expertise and sufficient resources to ensure compliance?
- What is the degree of technology automation to monitor transactions and to evaluate high-risk customers at the onset of a relationship?
- Are systems integrated across geography?
- Has the integrity of AML systems, including programming, data flows and mapping been tested to check whether the systems are working as intended?
These questions can dramatically help compliance officers determine where they need to focus their AML efforts in ensuring their organization is prepared for their AML Audit. If your firm needs help answering these questions or is needing guidance in working through some of the answers that came after asking, call the professionals at Cobia Compliance today! We want to partner with your firm to ensure your AML Audit is successful! Call us today for a consultation.