We draft, review and implement effective anti-money laundering and counter-terrorist financing (AML/CTF) Programs tailored to:

• Your organisational goals
• The size of your business
• Your operational structure and resources (human resources, technology, and budget)
• Your governance structure
• Your client base and jurisdictions of operation
• Applicable AML/CTF laws and regulations
• Sector-specific red flags and indicators
• Industry standards for AML/CFT compliance
• Business-specific risks, vulnerabilities, and ML/TF red flags identified in your AML/CTF Risk Assessment
• Your overall risk management framework and risk appetite for ML/TF risks
• AML/CFT controls testing methodologies
• AML/CFT controls testing triggers that would initiate ML/TF risk re-assessments
• Role-specific compliance responsibilities

 

We design AML/CTF programs to help you navigate the complexities of AML/CTF requirements in a commercially oriented and goal-focused manner, making it an effective cornerstone to support all aspects of AML/CTF compliance, including but not limited to:

• Initial and ongoing CDD and EDD processes
• Verification methods and requirements for identity, address, and source of funds
• Internal and external reporting
• Ongoing due diligence
• Transaction monitoring
• Employee vetting and training
• Suspicious activity detection and reporting
• PEP and sanctions screening
• Recordkeeping and reporting obligations

 

Service Coverage

We draft AML/CFT Programs (AML/CFT Programmes and BSA/AML Programs) for different types of reporting entities and designated service providers, including but not limited to:

• Investment bankers
• Investment firms
• Fund managers
• Brokers, including forex brokers
• Fintech companies
• Authorised and Non-bank deposit takers
• Non-bank lenders
• Online casinos and gambling platforms
• Currency exchange providers
• E-money issuers
• Money remitters and money transmitters
• 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
• Building societies
• Savings and loan associations
• Credit unions
• Corporate finance providers
• Finance companies
• Designated non-financial businesses and professions (DNFBPs), including trust and company formation providers (TCSPs)

 

Jurisdictional Coverage

Our countries of focus for this service include, but are not limited to:

• Australia: Where designated service providers are subject to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
• United Kingdom: Where relevant persons, including financial institutions and DNFBPs, are governed by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) (subsequently updated in 2019 and beyond)
• United States: Where financial institutions and other covered entities are subject to the Bank Secrecy Act (BSA), the USA PATRIOT Act and other relevant laws and regulations.
• Singapore: Where depending on their nature of business, reporting entities, including financial institutions and DNFBPs, may have to comply with different acts and notices, including Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA), Terrorism (Suppression of Financing) Act, Payment Services Act (PSA) and MAS Notices like MAS Notice 626, MAS Notice 1014, MAS Notice 824, MAS Notice PSN01, MAS Notice PSN0, etc.
• European Union: Where obliged entities, as defined in the 6th Anti-Money Laundering Directive (6AMLD), must meet AML/CFT obligations
• New Zealand: Where reporting entities are regulated under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) We have extensive experience in drafting and implementing AML/CFT Programmes for a variety of New Zealand reporting entities.
• Prominent Formation Centres

• Belize: Where reporting entities are regulated under the Money Laundering and Terrorism (Prevention) Act
• British Virgin Islands: Where reporting entities comply with the Proceeds of Criminal Conduct Act
• Cayman Islands: Where reporting entities are regulated under the Proceeds of Crime Act (2020 Revision) and the Anti-Money Laundering Regulations (2020 Revision).
• Jersey: Where relevant persons are governed by the Proceeds of Crime (Jersey) Law
• Malta:  Where subject persons are regulated under the Prevention of Money Laundering Act (PMLA)
• Dubai: Where reporting entities are governed by the Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations, along with its amendments and implementing regulations
• Bermuda: Reporting entities are subject to the Proceeds of Crime Act 1997 , the Anti-Terrorism (Financial and Other Measures) Act 2004 and other relevant laws and regulations
• Mauritius: Where reporting entities are governed by the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA)
• Seychelles: Where reporting entities are subject to the Anti-Money Laundering and Countering the Financing of Terrorism Act 2020
• Vanuatu: Where reporting entities are regulated under the Anti-Money Laundering and Counter-Terrorism Financing Act 2014

 

AML/CTF Programs Design

We focus on the effectiveness and efficiency of your AML/CFT Program to ensure it is fit for purpose in your circumstances, aligning it with:

• Applicable AML/CTF (aka CTF) laws
• Regulations

• Sector-specific red flags and indicators
• Industry standards for AML/CFT compliance
• AML/CTF supervisors' guidance
• Business-specific risks, vulnerabilities, and ML/TF red flags identified in your AML/CTF Risk Assessment
• Your overall risk management framework and risk appetite
• AML/CFT controls testing methodologies
• AML/CFT controls testing triggers that would initiate ML/TF risk re-assessments
• Role-specific compliance responsibilities

 

AML/CTF Programs Implementation

We offer a range of solutions to help businesses implement their AML/CFT programs successfully. These include but are not limited to:

 

Project Management

• Step-by-step program rollout
• Integration with existing compliance frameworks and programs
• Training staff involved in different areas of AML/CFT compliance

 

Procedures and Protocols

Creating a set of detailed procedures and process maps, protocols, and guidelines on all key aspects of the AML/CFT program so that each statement made there is backed up in reality. Our focus areas include, but are not limited to:

 

CDD and KYC

• Customer due diligence (CDD) procedures for onboarding
• Enhanced due diligence (EDD) for high-risk clients
• KYC verification for individuals, corporates, and trusts
• Risk profiling and client categorisation

 

Transaction Monitoring

• Real-time transaction monitoring systems
• Detection of large complex and unusual transactions and transaction patterns
• Addressing flagged transactions in compliance with the law and internal polices and procedures
• Application of risk-based transaction thresholds
• Integration with alert and trigger systems
• Clear escalation and reporting pathways

 

Material Changes

• Identification of material changes in client relationships
• Management of changes in ownership, domicile, and banking details
• Assessment of changes affecting ML/TF risk levels
• Procedural updates for addressing material changes

 

EDD and Account Investigations

• In-depth investigations for high-risk accounts
• Verification of sources of wealth and funds
• Application of advanced EDD measures
• Resolution of flagged accounts

 

Screening

• Sanctions, PEP, and adverse media screening
• Real-time updates for global watchlists
• Ongoing monitoring for changes in customer risk profiles
• Integration with automated screening tools

 

Red Flags and Alerts

• Identification of sector-specific red flags
• Real-time alert management systems
• Training for staff on recognising red flags
• Escalation procedures for identified risks

 

Ongoing Due Diligence and KYC Refresh

• Periodic reviews of customer profiles
• Updating KYC information based on risk triggers
• Ensuring alignment with regulatory requirements
• Integration of ongoing due diligence with monitoring frameworks

 

STR/SMR Reporting

• Guidelines for decision making
• Suspicious transaction report (STR), Suspicious activity report (SAR), Suspicious matter report (SMR) preparation and filing
• Compliance with reporting deadlines
• Training on identifying and documenting suspicious activities

 

Transactional Reporting

• Including prescribed transaction reporting (PTR), Threshold transaction reporting (TTR), etc

 

High-Risk Customers

• Identification and management of high-risk clients
• Enhanced monitoring and EDD for high-risk profiles
• Regular risk re-assessments
• Tailored controls for managing high-risk customers

 

AML/CFT Control testing

• Creating control testing methodologies tailored to your specific circumstances
• Incorporating ML/TF control testing into your compliance plan and calendar
• Tracking ML/TF control testing completion throughout the business
• Leading testing and refinement of implemented measures
• Communicating test results and necessary outcomes to your risk, compliance and managerial functions

We offer this service either as:

• A standalone solution
• As part of our internal AML/CFT review solution. Additional details about the service are available on our Internal AML/CFT Review page.
• As part of our AML/CFT statutory audit solution. You can find more information about the service on our AML/CFT Statutory Audit page.

 

AML/CTF Programs and Reg-Tech

Our focus areas for this service include:

• Needs Assessment
• AML/CFT Technology Selection: Tailored to your budget, operations, and compliance obligations, and covering customer digital onboarding, E-KYC, PEP and sanctions screening, transaction monitoring, etc.
• Assisting with testing to validate functionality, usability, and integration with operational, onboarding, risk and compliance management processes
• Implementation and customisation assistance across the business, including tailoring it to your AML/CFT procedures, triggers, alerts, etc.
• Streamlining internal documentation, including policies, procedures, workflows, and process maps, to accommodate the technology implementation

 

AML/CTF Program Enhancement

We offer AML/CTF program enhancements to increase its overall effectiveness, reflecting on:

• New compliance requirements and AML/CFT regulatory and guidance update adaptations
• Business growth and expansion
• Changes in risk ratings, risk appetite, risk assessment methodologies, emerging risks integration, etc
• AML/CFT auditors' and supervisors' findings, including identified deficiencies and breaches
• Results of previous internal controls testing
• Internally identified areas of improvement and gaps
• Changes in utilised AML/CFT technology
• Introduction of new products
• Best practice benchmarking
• Other triggering events

 

AML/CTF Programs Review

Regular AML/CFT Program reviews can help your compliance function and senior management effectively manage AML/CFT compliance. We offer thorough AML/CFT program reviews to assess its effectiveness and fitness for purpose. Our focus areas include identifying:

• Any gaps
• Points of improvement
• Required adjustments related to changes in your resources and operations
• Required adjustments related to the introduction of new products, expansion to new jurisdictions, and more
• Updates for regulatory changes and emerging AML/CFT risks

We offer this service either as:

• A standalone solution
• As part of our internal AML/CFT review solution. For more information about coverage, please visit our Internal AML/CFT Review page.
• As part of our AML/CFT statutory audit solution. For more information about coverage, please visit our AML/CFT Statutory Audit page.

 

AML/CTF Programs for Small Businesses and Startups

When it comes to AML/CFT compliance, it is better to be compliant than sorry. The obligations are straightforward, as are the expectations.

We develop AML/CFT programs for small businesses and startups, focusing on establishing foundational compliance practices that align with AML/CFT requirements and industry standards, allowing adjustment for future growth and continuous improvement as your business develops.

We focus on:

• Effective controls tailored to your specific business situation and AML/CTF Risk Assessment, avoiding generic templates that may not suit your business. (Some national AML/CFT (aka CTF) supervisors like AUSTRAC and others specifically recommend using generic templates without applying them to your situation).
• Cost-effective AML/CTF solutions
• Scalable AML/CFT programs for growing businesses
• Practical training for small teams, helping you apply your AML/CFT Program (AML/CFT Programme or BSA/AML Program) effectively

 

AML/CTF Programs for Company Groups

Managing AML/CTF compliance across different products and jurisdictions can be challenging. With years of experience supporting company groups in AML/CTF compliance management, we develop tailored AML/CTF programs that focus on:

• Standardised compliance across multiple entities
• Centralised monitoring and reporting systems
• Multi-jurisdictional AML/CFT program adaptation
• Coordination of group-wide risk management efforts
• AML/CFT controls fit for each product and local AML/CFT regulations and supervisor guidance
• Ensuring sufficient separation between entities to establish distinct compliance statuses, facilitating a smooth AML/CFT audit or regulatory review

 

AML/CTF Programs for High-risk Corporates

High-risk corporates face heightened regulatory scrutiny and reviews. With years of experience helping high-risk corporations manage their AML/CFT compliance and go through audits and reviews successfully, we offer AML/CFT programs that account for robust and holistic reviews. Our focus includes, but is not limited to:

• Effective resource allocation
• Training to the required standard
• Inter-department cooperation
• Complex, unusual and suspicious transaction-related scenarios
• Having an effective set of process maps and procedures to back up statements made in your AML/CFT program (including advanced escalation protocols for different scenarios and hot points for AML/CFT compliance, like handling material changes, EDD requirements for different scenarios, suspicious activity and transaction-related decision-making points).
• Handling higher ML/TF risks and complex clients throughout their journey
• Interaction between your AML/CFT obligations and risk appetite
• Adjustments to your program and underlying procedures and protocols following your AML/CFT control testing
• In-depth reporting where it is appropriate, coupled with distilling of information that needs to be escalated further up
• Advanced technology integration coupled with stress testing to identify and mitigate gaps that may arise from reduced human oversight or insufficient adaptability to evolving risks

 

Related Services

• AML/CFT Risk Assessments: We draft, review, and help businesses implement AML/CFT Risk Assessments that form the foundation of effective AML/CFT Programs. These assessments identify and address money laundering and terrorist financing risks while supporting the ongoing refinement of AML/CFT policies and controls. Visit our AML/CFT Risk Assessment page for more.
• AML/CFT Reg-tech Technology: We help with AML/CFT technology integration tailored to your circumstances.
• AML/CFT Training: We offer specialised AML/CFT training solutions for different reporting entities. Visit our AML/CFT Training page for more.
• AML/CFT Internal Review: We offer this confidential review solution to test your AML/CFT compliance and prepare you for a statutory audit or regulatory review.
• AML/CFT Statutory Audit: We provide both limited and reasonable assurance audit options. Visit our AML/CFT Audit page for more.
• AML/CTF Procedures: We assist in developing and enhancing AML/CTF 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/CTF 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.
• AML/CFT Advisory: We offer an advisory solution on a wide range of AML/CFT matters and issues, going beyond the ML/TF risk assessment. 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.