AML/CFT shield methodology: The eight step approach

After the 2013 amendments to AML/CFT, we created a shield methodology that stress tests your processes in order to protect your organisation against any vulnerabilities in your anti-money laundering programme. The shield is made of eight steps:

  1. Risk-based approach - We check to ensure you prioritise the riskiest areas of your operations, so that you can focus your efforts in the right places without running out of steam by taking on too much.
  2. Vetting and training - We make sure you are vetting the right people and training staff where it's needed.
  3. KYC - The key to an effective anti-money laundering operation is understanding your clients. We'll make sure your adverse media and PEP screening is targeting the right areas without you having to go through any irrelevant information.
  4. Record keeping - BDO will make sure you're keeping the right records for the correct length of time.
  5. Suspicious transaction and activity reporting - We'll help you understand what the regulator deems as suspicious, and apply red flag alerts to suspicious activity such as third-party payments or large, one-off payments. This is where our team's diverse background means experience such as investigative policing comes to the fore.
  6. PTR - We'll help you to meet your prescribed transaction reporting (PTR) requirements.
  7. Review and Audit - We'll conduct an internal review or independent audit and provide you with good practice improvement recommendations to ensure you are best protected against anti-money laundering vulnerabilities.
  8. Transactions that favour anonymity - We'll help you to ensure that, in today's online world, anonymity doesn't lead to criminal activity.

This eight-step approach allows us to proactively work with clients to ensure they are meeting their risk and compliance obligations. When clients have encountered any push-back from the regulatory bodies, we've helped them identify where they've gone wrong and what they need to do to fix it. Even when the regulator has given a small time-frame, we've helped our clients to address each and every issue raised, as well as finding any other areas that could cause problems further down the line.

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