Gap Analysis
The starting point of any engagement is normally to perform a Gap Analysis to ascertain the current status of a client’s AML & CFT policies and procedures.
This can be seen as a form of “health check” and is aimed at determining how the firm’s practices and infrastructure compare with what is required under current legislation.
Our detailed analysis of the client’s compliance infrastructure enables us to identify whether the current practices, policies and procedures are fit for purpose, and if not, to highlight any weaknesses and areas where remedial action is required.
The aim of a Gap Analysis is to evaluate the current situation and compare it to that which is desired or required.
We offer the Gap Analysis as a stand-alone service, or as the initial stage of our other services.
Preparation & Implementation of Development Plan
AML & CFT Compliance is dynamic by nature, with obliged entities having to constantly monitor and update their procedures and practices, so as to keep up with everchanging legislation.
Following the completion of a Gap Analysis, and based on our discussions with Senior Management regarding their desired end-goals, we prepare a development plan highlighting all the areas where remedial action is required, as well as what needs to be done.
Thereafter we can either be appointed to implement the changes, or this can be done internally by the client.
The main areas that are addressed by the development step-plan are:
- AML & CFT Manual and staff awareness training
- Compliance infrastructure
- Application of Risk Based Approach
- Economic profiles
- KYC documentation
- Simplified & enhanced due diligence
- Record keeping
- Reliance on third parties for KYC
- Staff training
Ongoing Monitoring
As has already been mentioned, AML & CFT Compliance is a dynamic discipline, with each new round of legislation placing a heavier burden on obliged entities and their scarce resources of time and money, and where non-compliance is no longer an option in view of the catastrophic sanctions that can be imposed by regulators.
Based on the size, client profiles and requirements of Senior Management, Aequus Business Consulting can be engaged to perform regular monitoring visits to ensure that the AML & CFT Compliance infrastructure is being properly applied, updated and maintained. This service can be offered in the form of consultancy, or if required via formal appointment as Internal Auditor.
Each visit will be structured so as to review:
- Preparation of end-of-visit report with performance evaluation and recommended improvements
- Staff training
- Internal/external reporting & new client acceptance/rejection
- Sample of client files
Ad Hoc Services
In addition to the three levels of services already described, Aequus Business Consulting can undertake various assignments on an ad hoc basis as and when required.
Examples would be to:
- Assist with the preparation for an AML audit by the relevant Supervisory Authority
- Review and update internal AML manuals
- Drafting of specific documents, such as Economic Profiles, Client Acceptance Forms, etc
