For this client, we provided a complete overhaul and uplift of their Line 1 AML function following findings from an independent review.
For this we restructured the process for new and ongoing screening of the investors. Following this, TM rules were redesigned to capture the relevant ML/TF risks the business faced. An ECDD report template was introduced, along with a thorough procedure to identify high risk customers and the standard to complete ECDD's. A fund screening process was also introduced.
For this client, Line 2 support was also necessary. The support and advice provided ensured the client could rely on Chapter 28 of the AML rules when purchasing a new business.
For this client, we developed and implemented a new TM Report Template. This was followed up with extensive training and support for the current staff to meet the new standard for detail in the TM Review. Following this, we were used as key personnel in onboarding of new staff.
A large portion of support came in the form of TM Quality Control (QC). Here we built a reporting tool to gain insights from the QC being performed. We were able to identify common rules and aspects of the template staff struggled with. This then drove monthly training and helped identify which staff needed support.
We have experience with two clients providing support and guidance on KYC remediations. We have provided on guidance on when KYC is required to be received, the attempts to be made, and the actions to take when no response is provided. We have remediated various entity types such as Trusts, Private Companies, Corporate Trustees, NGOs, Foreign Companies and Trusts and Charities.
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