Anti-Money Laundering &
Counter-Terrorist Financing

Performing an independent assessment of the health of your financial crime function. We will tailor the scope of the health check to your requirements. It may include reviewing client onboarding, client due diligence, client risk rating, screening, transaction monitoring, suspicious activity report (SAR) filing and/or overarching governance.

Helping you understand the specific ways in which criminals may attempt to exploit your organisation to launder money or finance terrorism. This is based on the unique aspects of your business such as countries of operation, customer base and product offerings.

Once your unique set of risks are understood via a risk assessment, targeted controls must be put in place to address these risks directly. The control framework will need to consider your existing control landscape and define how your risks can be effectively and efficiently mitigated by people supported by relevant technologies and processes.

Understanding the intricacies of your customers is a key element of an effective financial crime control framework. We help our clients to understand the most pertinent data points required to understand the risk of a customer presents based on their customer type, how to continuously refresh this data efficiently, and how to use trigger-based models to achieve perpetual KYC. We also have extensive experience working with, and optimising, CLM systems to embed effective KYC processes.

Monitoring transactions for suspicions of ML or TF at volume is a complex problem which requires careful design to be effective at both highlighting unusual/potential suspicious activity and being operationally efficient. Aspects such as data ingestion and transformation, scenario design (based on underlying risks), customer segmentation, case management, workflow and investigation aids need particular focus.

We specialise in the design, implementation and optimisation of these systems for clients – whether systems have been built internally or utilise a 3rd party vendor solution.

The use of 3rd party software may be advantageous to help you meet your objectives and compliance obligations. We can help identify, engage, assess and select the best technology partner for your specific business and problem statement.

We can assist you with the creation, review, and enhancement of your AML policies to ensure these are tailored to your specific risk appetite and applicable regulatory requirements.

We also have considerable experience defining procedures that define how alerts (e.g. name/payment screening or transaction monitoring alerts) should be investigated in order to establish true matches from false matches or suspicious behaviour from unusual behaviour.

Designing and delivering customized AML & CTF training programs for your employees to embed a strong culture of compliance. We have previously delivered training to senior executives and board members, through to team leaders and operational staff.

We can conduct independent testing of your AML controls to ensure they are effective, providing observations and prioritised recommendations for improvement based on our findings. Example controls include name screening, customer risk rating and transaction monitoring.