Independent AML Compliance Audit

Financial services firms in the UK are normally required by their suppliers, such as Banks, Acquirer, Payout agents, Cash processors, Currency wholesaler, E-money issuer or Principal firms, to have a periodic/annual Independent External Anti Money Laundering Compliance Audit.

The popularity of External AML Audit reports is growing fast because of the fact that most small to medium-sized financial firms do not have separate compliance and internal control systems to monitor it, or dedicated personnel to focus solely on AML compliance. At the same time in larger firms, things are more complicated and the compliance officers are often overwhelmed trying to keep up with the latest industry practices and compliance requirements.

GoCompliance’s independent review helps the firms to ensure that AML compliance controls are risk-ready. Our certified AML specialists serve the client as an advisor through the entire Audit process.We apply a proven 3-phases procedure to assess clients, assess the compliance program, identify gaps, and propose unbiased, objective view recommended enhancements.

Phase One:

In order to gain a deep understanding of your business, GoCompliance Advisors will review relevant documents, speak to senior management in detail and run sample tests. Phase one of our AML Audit procedures is about Identifying any gaps, shortcomings and deficiencies.

This Phase features a thorough review of program documents, including but not limited to:

Business model and infrastructure
Business model and infrastructure
Systems and controls
Threshold conditions
Fitness and propriety
Fitness and propriety
AML policies and procedures documentation
AML policies and procedures documentation
Previous independent testing report (if any) and management responses

Phase Two:

We conduct an onsite visit in the Phase Two which includes:

Interviews with key personnel
Walk-through of compliance operations processes
Testing of transactions
A brief exit meeting with senior management to discuss preliminary conclusions

Gaps and shortcomings are normally identified in this stage and our advisors will list the needed enhancements too. Recommendations are tailored to each client. Clients are notified on what standards need to be reached, and what regulators will expect to see.

Phase Three:

GoCompliance advisors will set some realistic action steps for clients to implement to address the shortcomings.

Phase Three consists of:

Analysis of review and test items:
Comprehensive report including:
Requirements
Observations
Testing
Recommendations
Comprehensive cover letter addressing the senior management