Anti-money laundering advisory services
ATW helps organizations meet their business objectives 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 service offering
ATW has assisted individual’s and many 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
- Lawyers and other financial services professionals with AML and industry experience.
For more information contact us on firstname.lastname@example.org