AML/CFT Audit Solutions | Independent| Professional Approach | Practical Audit Reports

Effective AML/CFT Audit Solutions for financial institutions and reporting entities | AML Compliance Audits across key industries | Real AML Audit Experience | AML Auditors who know what they are doing | Practical Audit Reports

With over 15 years of experience in Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) compliance, we offer AML/CFT audit solutions to a wide range of financial institutions, financial service providers, DNFBPs and other types of AML/CFT reporting entities.

 

AML Audit Solutions’ Scope

We offer our AML/CFT audit solution to the following reporting entities and designated service providers:

  • Investment bankers
  • Investment firms
  • Fund managers
  • Brokers, including forex brokers
  • Fintech companies
  • Non-bank deposit takers
  • Non-bank lenders
  • Online casinos and gambling platforms
  • Currency exchange providers
  • E-money issuers
  • Money remitters
  • Payment gateway providers
  • Derivatives issuers and platforms
  • Neo-banks
  • P2P lending platforms
  • Crowdfunding services and platforms
  • Financial advisers
  • Investment advisers
  • Wealth managers
  • Custodial or depository service providers
  • Consumer credit providers
  • Credit unions
  • Corporate finance providers
  • Finance companies
  • Designated non-financial businesses and professions (DNFBPs), including trust and company formation providers (TCSPs)

 

Our AML/CFT Audit Solution covers compliance with requirements in the following countries:

 

AML/CFT Audit’s Focus

Value-Added AML/CFT Compliance Audit of your key documents, procedures, processes, controls, and protocols | Flexible AML/CFT Audit Options | Experienced AML/CFT AuditorsWe cover compulsory AML/CFT audit requirements as outlined in the applicable AML/CFT laws and regulations. We also cover applicable AML/CFT supervisor’s expectations. AML/CFT Audit requirements generally cover policies, procedures, and controls. However, this varies, depending on the local requirements. Our focus areas include, but are not limited to:

  • AML/CFT Risk Assessment Audit, including a review of:
    • Whether it identifies the risks faced by your business
    • Whether there are checks in place to ensure it is up to date
    • Whether it enables you to determine the level of risk involved in relation to various AML/CFT obligations. We cover the five key ML/TF risk areas: products, size and complexity, delivery channels, the countries you engage with, and the institutions you deal with
  • AML/CFT Program Audit, including a review of:
    • Whether your AML/CFT program is functioning in practice as intended
    • Whether it complies with the requirements in the local AML/CFT law and regulations
  • Whether you comply with your obligations under the AML/CFT laws, including, but not limited to:
    • Initial customer due diligence requirements, including simple, standard, and enhanced due diligence
    • Screening
    • Beneficial ownership identification
    • Record-keeping
    • Customer risk rating
    • Triggers and processes for customer risk re-assessment
    • Ongoing customer due diligence for different risk categories of clients, including triggers for ongoing due diligence
    • Transaction monitoring, covering the detection and handling of large, unusual, and suspicious transactions and patterns
    • Reporting timeliness and accuracy
    • Governance and oversight
    • Staff vetting and training
    • Obligations covering the detection, escalation, and reporting of suspicious activities (SARs) and suspicious transactions (STRs), along with other statutory reporting obligations, including cross-border transactional reporting, etc.
  • AML/CFT Framework Application review, including the following areas:
    • Whether the policies, procedures, and controls based on your AML/CFT Risk Assessment have been adequately designed and operate effectively
    • Conducting limited assurance testing of AML/CFT controls, including but not limited to CDD, ODD, transaction monitoring, recordkeeping, etc.
    • Verifying the operational effectiveness of reporting systems
    • Assessing the extent to which employees understand and comply with your AML/CFT program
    • The implementation of your AML/CFT program or equivalent arrangements by branches, subsidiaries, and outsourced providers
    • Reviewing how any previously identified deficiencies or non-compliance areas have been addressed
    • Assessing the adequacy of your AML/CFT employee training program
  • Accepted AML/CFT Guidance: Whether Risk Assessment, AML/CFT policies and other key AML/CFT protocols are based on guidance materials published or accepted by your AML/CFT supervisors

 

AML/CFT Auditors’ Requirements

If you search for an AML/CFT audit firm online, everyone claims to be an expert, uses puffery language that AI chatbots write for them, and so on and so forth.

We are not just another AML/CFT audit provider firm that claims to have extensive knowledge of AML/CFT compliance.

We are the ones who know what we are doing, having years of experience in all aspects of AML/CFT compliance, including:

  • Creating and successfully enhancing anti-money laundering and counter-terrorist financing frameworks for different businesses, tailored to their specific product, resources, risk appetites and sector-specific money laundering and terrorism financing (ML/TF) risks
  • Conducting AML/CFT risk assessments through a wide range of reporting entities
  • Handling the first, second, and third lines of AML/CFT compliance and management.
  • Conducting internal AML/CFT audits that go beyond statutory requirements
  • Successfully assisting businesses in going through statutory AML/CFT reviews, including those conducted by the top four. We know a thing or two about good and bad AML auditors
  • Designing and testing AML/CFT controls, ensuring they are both practical and effective in addressing ML/TF risks
  • Acting as external AML/CFT auditors for FIs and DNFBPs
  • Helping FIs and DNFBPs when things go wrong, including coordinating their risk and compliance teams, legal teams, external lawyers, and operations teams
  • Helping different reporting entities to  effectively  communicate with local AML/CFT supervisors
  • Successfully leading businesses through desktop and onsite regulatory reviews
  • Helping different reporting entities with their AML/CFT remediation

We know first-hand what businesses want from their AML/CFT auditors.

 

AML/CFT Audit Methodology

We can select and apply appropriate audit and control testing methodologies, taking into account:

  • Your business size
  • Your products
  • The complexity of the business
  • Your ML/TF risk levels

Alternatively, we can conduct an AML/CFT review using your audit methodology.

 

AML/CFT Audit Types

We can help you with the following types of AML/CFT audits:

  • Statutory Audit Periods: Set out in your local AML/CFT laws. Generally, it varies from country to country, with some countries like New Zealand having prescribed audit periods in their laws and others basing it on the ML/TF risk level of the business
  • Directed AML/CFT Audit: An AML/CFT supervisor can direct a reporting entity to undergo an AML/CFT audit at any time.
  • Audits with internal deadlines: These are generally a part of an AML/CFT Program and or wider compliance risk management plans, where an organisation sets up a period for their AML/CFT audit.
  • AML/CFT Audits Compliance by Decision: A reporting entity may engage an AML/CFT auditor through an internal decision. Common audit triggers include:
    • Substantial changes in the markets of operations and customer types
    • Introduction of new products
    • Changes in delivery methods for their services
    • Structural changes to the business
    • Changes to the ML/TF risk level of the business
    • Interactions with their AML/CFT supervisor
    • Changes in fund deposit or withdrawal methods
    • Changes in outsourcing arrangements for ML/TF prevention functions
    • Substantial changes to their AML/CFT Program
    • Changes to the number or volume of transactions
    • AML/CFT remediation issues faced or completed by the business

 

Effective AML Audit Reports

We issue detailed AML/CFT audit reports aligned with your local AML/CFT requirements and expectations. These reports may vary depending on the local requirements and engagement level, but may include the following key areas:

  • Audit Basis: The relevant AML/CFT requirements and standards applied during the audit to assess your AML/CFT Risk Assessment and AML/CFT program
  • Scope and Approach:
  • What was examined and tested (policies, controls, procedures) during the audit and how your AML/CFT Program was assessed against the required compliance standards.
  • What methodologies were used for testing
  • Audit Findings:
  • Clear documentation of areas of compliance and non-compliance, covering all primary aspects of your AML/CFT program.
  • Identification of areas of compliance and non-compliance
  • Audit Outcomes: An evaluation of whether:
  • Your AML/CFT Risk Assessment and AML/CFT Program meet compliance requirements
  • We observed your AML/CFT Program to be adequate and effective over the specified period
  • Changes are required due to deficiencies in your AML/CFT Risk Assessment or AML/CFT Program.
  • Actionable Recommendations (Optional): Steps needed to address non-compliance and suggested improvements

 

AML/CFT Audit Process & Milestones

The AML/CFT Audit process generally involves:

  • Initial Meeting & Scope Definition:
  • Defining the scope and objectives of the audit with the reporting entity
  • Understanding the entity’s business, risk profile, and existing AML/CFT Program
  • Documentation Review:  Reviewing key AML/CFT documents
  • Sampling & Testing: Performing sampling and testing of compliance with the AML/CFT laws and the AML/CFT Program. Examples include:
  • Testing CDD procedures (customer identification and verification).
  • Reviewing transaction monitoring alerts and SAR investigations.
  • Assessing the effectiveness of the risk assessment process.
  • AML/CFT Controls testing (if applicable)
  • Interviews & Inquiries:
  • Interviewing key personnel (compliance officers, management, front-line staff)
  • Inquiring about the implementation and effectiveness of AML/CFT controls
  • Application of Audit Methodology:
  • Applying appropriate audit methodologies, such as risk-based auditing, to assess the effectiveness of the AML/CFT Program
  • Report Preparation & Presentation:
  • Preparing a comprehensive audit report
  • Presenting findings, conclusions, and recommendations to management

 

AML/CFT Audit and Information Sampling

AML audit requirements focus on evaluating how effectively a reporting entity complies with its obligations under the local AML/CFT laws and regulations, as well as its AML/CFT Program. Independent audits typically involve reviewing samples of:

  • Individual customers, including resident and non-resident clients, various types of corporate clients (e.g., companies, limited partnerships, and entities with complex beneficial ownership structures), as well as trusts and investment vehicles
  • Customers presenting different ML/TF risks, including those categorised as medium- or high-risk
  • Large, complex, or unusual transactions to determine how effectively the entity meets its transaction monitoring obligations
  • Ad hoc and periodic reports on customer transactions and activities, such as suspicious activity reports (SARs), suspicious transaction reports (STRs), Suspicious Matter reports (SMRs) and reports covering international movement of funds over certain thresholds, cash deposits over a certain sum and other transactional reports, to assess compliance with AML/CFT reporting obligations.
  • AML/CFT training and staff vetting records
  • Specialised client and transactional registers (e.g., high-risk clients, politically exposed persons (PEP) registers, etc.)
  • Materials aimed at enhancing ML/TF risk awareness and operational compliance
  • Records maintained for clients or/and/or transactions to verify compliance with record-keeping obligations under the local AML/CFT laws

 

AML/CFT Audit Solution Tailored to Your Needs

When it comes to delivery, we:

  • Focus on clear, concise, and objective assessments. No ego, no attitude, no puffery, and no jargon
  • Have real knowledge of AML/CFT compliance and how each aspect works
  • Use a client-centric approach. We understand the difference between your risk appetite, internal procedures, and AML/CFT requirements
  • Cause minimal interruptions to your business (combining onsite and remote engagements)
  • Provide comprehensive audit reporting

When it comes to flexibility, we:

  • Offer realistic pricing options
  • Tailor our approach to your specific needs and risk profile, offering limited assurance, reasonable assurance, and holistic options. We offer AML audit solutions to:
  • Small businesses and startups
  • Mid-sized businesses
  • Business groups, including those with centralised compliance functions across subsidiaries, those operating across different compliance regimes, and offering a range of products
  • High-risk corporates that come under regulatory scrutiny and pressure from important stakeholders, such as banking partners, insurance providers, and money remittance channels

 

AML/CFT Audit Preparation 

We offer a comprehensive Internal AML Review Solution with the following features:

  • Deeper Audit Focus, including:
  • Evaluating the effectiveness of your AML/CFT compliance against your business goals, future objectives, wider risk appetite, and more
  • Deep diving into the effectiveness of AML/CFT controls
  • Covering specific review areas such as AML technology, process optimisation, and more.
  • Flexible Scope: Designed with a flexible audit scope, which can be customised to your needs, as opposed to the AML/CFT audit under the local AML/CFT laws and regulations
  • External Audit Preparation: Focused on internal improvement and identifying issues before external scrutiny, helping you prepare for an external AML/CFT audit, an enhanced review by a banking partner
  • Regulatory review Preparation: Focused on preparing you for a review by the DIA, FMA or RBNZ
  • Non-binding findings: The audit report is confidential, giving you the opportunity to address any identified issues discreetly
  • More information: Visit our Internal AML Review Solution page for more information

 

Related AML/CFT Solutions

In addition to our AML/CFT compliance audit option, we offer a comprehensive set of AML/CFT compliance solutions to help you navigate the complexities of various AML/CFT requirements in a commercially oriented and goal-focused manner, providing effective support for all aspects of anti-money laundering compliance. Our focus areas include, but are not limited to:

  • AML/CFT Advisory: We provide advisory solutions on a wide range of AML/CFT matters and issues. Visit our AML/CFT Advisory page for more.
  • AML/CFT Compliance Management: We can fully manage your anti-money laundering and terrorist financing compliance. Visit our AML/CFT Compliance Management page for more.
  • AML/CFT Risk Assessments: We conduct, review, and assist businesses in implementing AML/CFT Risk Assessments that form the foundation of effective AML/CFT Programs. Visit our AML/CFT Risk Assessment page for more.
  • AML/CFT Programs: We draft, review, and assist businesses in implementing AML/CFT Compliance Programs based on the ML/TF risk assessment outcomes. Visit our AML/CFT Program page for more.
  • AML/CFT Reg-tech Solutions: We assist with AML/CFT technology integration tailored to your specific needs.
  • AML/CFT Training: We offer specialised AML/CFT training solutions for different reporting entities. Visit our AML/CFT Training page for more.
  • AML/CFT Procedures: We assist in developing and enhancing AML/CFT procedures tailored to your business needs, focusing on effective AML risk management across business processes.
  • AML Manuals and Guidelines: We create and refine practical resources such as AML operating manuals and guidelines that provide step-by-step instructions to ensure efficient AML/CFT compliance based on your business size and complexity.
  • ML/TF Controls Mapping: We help map, assess, and enhance internal ML/TF controls to ensure compliance, address financial crime risks, and respond to findings from AML/CFT audits and supervisors.
  • AML Red Flag Protocols: We develop guidelines for identifying and responding to red flags, enabling timely action against fraud, money laundering, and terrorist financing activities under various operational circumstances.