Anti-money laundering advisory services

ATW helps small and large organizations  to meet  their business goals by delivering a range of advisory services designed to help  enhance risk management  activities  and improve business processes. From our network of member firms around the world, ATW's advisory professionals offer services  that  help clients assess, improve, and monitor their business risks.

 AML regulatory environment

The Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (the "AMLO") has been in effect since 1 April 2012.

The AMLO  introduces a more robust infrastructure for sanctions against financial institutions and  their senior management,  codify and  strengthens expectations  that have hitherto  been  only set out in guidance, and brings under statutory  regulation some other areas  that  had not previously been covered.

The four regulators (i.e., the Hong Kong Monetary Authority, Securities & Futures Commission of Hong Kong, Hong Kong Customs and Excise Department and Office of the Commissioner of Insurance) issued the new AML guidelines in Jan 2012 to coincide with the commencement of the AMLO .

Individual members of senior management will be exposed to the possibility of personal penalties in the event that AML systems are found wanting (maximum fine of HK$1M and to imprisonment for 7 years).

HKMA further requires Authorized Institutions to build a robust and  effective Anti-Money Laundering and Counter-Terrorist Financing regimes  to combat laundering the proceeds of tax crime effective  from Jun 2013.

The HKMA recently announced that there would likely be significant AML/CFT related  fines forthcoming.    HKMA focus areas include tax evasion, Correspondent Banking and RMA and Transaction Monitoring.

What are the key challenges?

The increased emphasis by regulators in most countries, and changing rules, has Catapulted AML onto nearly every financial services organization's strategic risk and control governance agenda.

Boards of directors, executive  management,  compliance,  operations and internal  audit recognize that failure to  maintain  an  effective  AML program could lead  to fines, costly litigation, prison sentences  for  board members  and executive management,  strategic failures,  as well as harm to  an organization's reputation.

To meet new requirements and supervisory expectations, financial institutions should consider some of the key issues we have noted when reviewing AML .


  • Insufficient management oversight.
  • Inadequate independent monitoring procedures.
  • Lack of segregation of duties on key processes.
  • Outdated policies and procedures.
  • Lack of record-keeping and evidence of controls.
  • Inappropriate and inadequate staff training.
  • Inadequate risk assessment .
  • Improper threshold settings .
  • RMA Exchange and Correspondent Banking.

 An efficient and effective approach to AML .

Money laundering detection and  prevention  requires a significant investment  in resources to develop,  implement,  and enforce an effective  AML program. As a result, there is a focus on improving the efficiency  of programs. Organizations should consider a risk-based approach for their company's program to  address regulatory expectations,  optimize spending and provide global coverage.

ATW AML advisory services  assist financial services  companies identify money laundering risk, detect  suspicious activity,  comply with  regulations and leverage technology. Our approach also  helps clients  carefully  consider important trade-offs for additional investments  in AML programs and  technology solutions.

Ways to improve AML efficiency and effectiveness

Understand business, products, initiatives and distribution channels; validate risk profile; identify control gaps and improvement opportunities.

Improve the design and/or operating effectiveness of processes and controls,  leveraging  leading practices  and process improvement techniques.

 Validate that processes are operating as designed, controls are effective, and risks are managed

 ATW AML Services

ATW has assisted individual’s and numerous leading financial  services companies  in identifying  money laundering risk, reviewing  controls over  suspicious activity,  assessment of compliance with regulations and leveraging  technology.

Our services include:

  • Perform an overall and product specific AML risk assessment.
  • Perform an independent assessment of AML controls design and operating
  • Evaluate and/or assist with the development of AML policies and procedures and with the selection  and  implementation  of AML software tools and techniques.
  • Evaluate high risk clients  and client risk ranking methodologies.
  • Improve and help Optimize AML transaction monitoring tools and techniques.
  • Perform detailed AML transaction  testing  in response to regulatory and/or supervisory requirements
  • Assist in remediation of AML issues

Our professional AML team  works in many countries in which financial services  firms conduct business. Our subject matter professionals bring hands-on experience  in assessing, improving and  monitoring AML programs for all types  of financial services companies, ranging from banks to insurance companies  to asset managers.

  • Based on your needs, our client serving team may include:
  • Former senior level regulators
  • Certified anti-money laundering specialists
  • Certified public accountants
  • Certified internal auditors
  • Certified fraud examiners
  • Information technology professionals
  • Bankers
  • Lawyers and other financial  services professionals with AML and industry experience.

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