1 GETTING STARTED USING THE AML ACCELERATE PLATFORM
1.1 Delivering AML compliance
The AML Accelerate platform has been designed to support business regulated for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) to become compliant with the AML/CFT laws and regulations it is subject to.
The AML Accelerate platform has been built by AML/CFT experts and has been designed to be an easy and efficient solution to AML/CFT compliance that can be used by those that have limited or no AML/CFT compliance knowledge or experience.
The AML Accelerate platform is designed to deliver the foundational AML/CFT compliance documents a regulated business requires and support for on-going compliance.
AML Accelerate’s platform is structured to guide you through the creation of the foundational AML/CFT compliance materials:
- Company Information and Context provides comprehensive information about a business that will contextualise an organisation’s Money Laundering / Terrorist Financing (ML/TF) risk profile
- An ML/TF Risk Assessment that allows a business to identify, assess, mitigate and manage the ML/TF risks faced
- An AML Program/Policy that sets out the controls that address the legal and regulatory AML/CFT obligations
- Customer Due Diligence Standards that set out what information a business needs to collect and verify on their customers
- An AML Operating Manual that guides a business through the controls that will be required to be implemented.
- An Action Plan where users are provided with guidance on how to implement and improve their Anti-Money Laundering Program.
Use of the AML Accelerate platform and the creation of these documents is performed in the platform that has been specifically designed to guide you through completion of the ML/TF risk assessment, the AML program, the Customer Due Diligence standards and, the Operational Manual as well as, the Action Plan, all of which come as standard with an AML Accelerate license.
Nevertheless, there is information about a business and organisation that is useful to have to hand before you start to use the AML Accelerate platform. Having this information readily available will help you move through the platform and complete the work required to create your AML Program Manual.
1.2 Making the right choices
When you register for the AML Accelerate platform it is important to make the right choices so that AML Accelerate can deliver the right solution for your business or organisation.
When registering it is important to select the right country (where the business is located) and the correct industry group and industry (note, multiple industries can be selected within the Industry Group at no extra cost so it is recommended that all industries are selected).
Making the correct choices will allow the AML Accelerate platform to deliver the correct solution to support your organisation in addressing its AML/CTF compliance obligations.
This includes the correct AML program and customer due diligence standards for the country the business is located in and relevant to the industry or industries it operates in.
1.3 Creating an AML Program Manual
Once you have completed the registration process, you will be required to create an AML Program Manual, which will appear in the Audit History page.
To start developing the AML Program Manual simply click on the “New AML Program Manual” button.
Once you complete the Company Information section move to the ML/TF Risk Assessment section which will take you through an assessment of different categories and sub-categories of ML/TF risk, including:
- Environmental Risk
- Customer Risk
- Business Risk
- Channel Risk
- Product and Services Risk
- Country Risk
2 CONDUCTING THE ML/TF RISK ASSESSMENT
2.1 Environmental Risk
Environmental risk considers the external and internal environments that an organisation operates in. Through completion of the risk assessment, you are guided to assess your organisations’ vulnerability to crimes that can give rise to ML/TF (predicate crimes), either because a customer is involved in the commission of one or more predicate crimes and/or is seeking to use products or services to launder the proceeds of a predicate crime.
The AML Accelerate platform groups predicate crimes into several categories to assist the assessment. These groups are deceptive crimes, illicit trafficking, property crimes, and crimes against the person (personal crimes).
The ML/TF environmental risk assessment also guides you to assess the internal vulnerability of the organisation to being used to launder money, finance terrorism, or breach targeted financial sanctions.
In addition, the ML/TF environmental risk assessment includes an assessment of whether your organisation is vulnerable to non-compliance with relevant AML/CFT law and regulation if it does not put in place appropriate controls or implement adequate responses to AML/CFT obligations.
Like all parts of the AML Accelerate risk assessment, environmental ML/TF risk is assessed at the inherent risk and residual risk level.
2.2 Customer Risk
Customer risk is the risk or vulnerability that an organisation’s customers may be involved in money laundering or terrorist financing activities. ML/TF customer risk is significantly influenced by the nature and/or attributes of the organisation’s customer.
The risk assessment assesses customer ML/TF risk at an enterprise level, and the AML Accelerate platform calculates customer risk as the combination of:
- The customer footprint within the customer base, which consists of their geographic location and if they are engaged in business activities that are vulnerable to ML/TF; and
- The types of customer within the customer base, which consists of whether they are Politically Exposed Persons (PEP) and their legal forms vulnerabilities to ML/TF risk.
2.3 Business Risk
Business risk is the risk or vulnerability of a business’s operations to money laundering or terrorist financing activities. ML/TF business risk is significantly influenced by where the business operations are located, the use of third parties, and the ML/TF risks resulting from employees.
The risk assessment assesses the business's ML/TF risk as the combination of business operations risk and employee risk.
2.4 Channel Risk
Channel risk is significantly influenced by the nature and/or attributes of the channels used to deliver products and services to customers.
Channel risk is determined by whether the delivery of a product or service involves face to face contact with the customer, and the use of third parties as part of the delivery chain of a product or service.
2.5 Product and Services Risk
Product risk is significantly influenced by the nature and/or attributes of products and services.
Product or service risk is determined through the AML Accelerate platform by assessing whether the attributes of a product or service offer functionality the customer can use to facilitate money laundering and/or terrorist financing.
2.6 Country Risk
Country risk is the assessment of a country’s or jurisdiction’s vulnerability to money laundering, terrorism financing, and targeted financial sanctions.
AML Accelerate delivers a standard ML/TF country risk assessment for over 260 countries and territories which are used as part of Customer, Business, and Channel risk.
2.7 More information on the ML/TF risk assessment
For more information on the ML/TF Risk Assessment please refer to the ML/TF Risk Assessment Methodology within the AML Accelerate platform.
3 CREATING THE AML PROGRAM
Once the ML/TF risk assessment has been completed, the AML Accelerate platform generates a draft AML Program, based on the country and industry selected.
The AML Program should be fully reviewed by the user, and the text highlighted in yellow amended to the circumstances of the organisation.
4 CUSTOMER DUE DILIGENCE (CDD) STANDARDS
Once the AML Program has been completed, the AML Accelerate platform guides the user to review and edit the CDD Standards provided by the AML Accelerate platform, based on the country selected.
The CDD Standards should be fully reviewed by the user, and the text highlighted in yellow amended to the circumstances of the organisation.
The AML Accelerate platform also provides a number of appendices to support the other documents provided. The Appendices included a Glossary of Terms, a Reference Library, and full Country Risk Assessment ratings.
The AML Accelerate platform allows the user to add to the Glossary of Terms and Reference Library if required.
6 REVIEWING, PUBLISHING AND ADOPTING THE AML PROGRAM AND THE ACTION PLAN
Once the AML Program Manual has been created on the AML Accelerate platform it should be reviewed to ensure that all the information is correct.
AML Accelerate comes with a suggested action plan where users are provided with guidance on how to implement and improve their Anti-Money Laundering Program.
As part of the review mode, the ML/TF risk assessment results are displayed and the user can add additional commentary regarding the results of the risk assessment.
The Action Plan first appears as the last step in the review process and has a number of sections.
The first section is, “Unknown Risk Areas”, which summarises any risk factors that were assessed as “unknown” during the review, which indicates that either the data was unavailable or not assessed, either way, results in a negative impact to the overall risk assessment and this section contains a list of further actions that could be taken to develop a deeper understanding of these areas within the assessment.
The second section is “Additional Controls to Consider”, which summarises all mitigating controls that were not selected, since these once implemented and operating effectively have the effect of reducing the residual risk score as positive steps have been taken to mitigate and manage the identified money laundering and terrorism financing risk, so this section provides a list of recommended controls that the organisation could implement to improve the management of its AML/CFT risk exposure.
The third section is “Control Effectiveness”, which summarises all risk categories, where a control has either not been tested, or where it has, it was assessed as needing improvement (ineffective control) and consequently will impact the residual risk score and it is recommended to test and improve those controls that are listed.
The fourth section is “Action/Issue Summary”, which summarises any actions or issues that have been entered against each of the Risk Categories, which should be completed as part of the continuous review and improvement cycle of the risk management process.
The final section in the action plan is for “Practical and Actionable Steps”, which provides a list of recommended actions that can be taken to implement and embed effective risk-based systems, procedures, and controls into the AML program.
After the AML Program Manual has been published, you can view from the Audit History.