AML SYSTEMS AML Compliance requires technology and data support operations and include; Processes for; • On-boarding and identity verification systems at account opening • Transaction monitoring • Watchlist and sanctions filtering systems • Ongoing account activity and customer review
2
Quality compliance data is integral to; • AML compliance processes • Compliance data is needed across the entire cycle of AML compliance • Watchlists and enhanced compliance databases should be used across every stage of AML compliance including; » Initial account opening » Ongoing monitoring of transactions/arrangements » Periodic review of the customer base » Screening international payments
3
Effective case management systems are needed to: • Enable compliance analysts to investigate • Report on suspicious activity • Provide robust historical auditable data
SA M
PL E
1
CYCLICAL RISK BASED AML MANAGEMENT
AML policy & procedures review
AML PROGRAMME PLAN
AML organisation design
AML training
AML SURVEILLANCE
Annual AML risk assessment
AML REPORTING
EXTERNAL
External influences
FATF + other bodies
Regulations and legislation
Pressure from regulators
Global trends + cases
Fig.9
15
Restart
BUSINESS
CONTROL
Time AML risk assessment & strategy