7. Reviewing, publishing and adopting the AML Program and the Action Plan

1. Overview

At the end of the process to create an AML Program, the user will have completed the following steps and be at the point where this is ready to be reviewed, published, and formally adopted:

• Company Information
• ML/TF Risk Assessment
• AML Program
• Customer Due Diligence Standards
• Appendices

The review step is the first time in the process where the user will be presented with the resulting ML/TF risk score based on the answers provided during the initial data entry and by jumping back to the relevant section and clicking edit the user can modify any of the answers prior to publishing the AML Program.

For Adviser License Holders, it is recommended that one of the appointments is used to review the full contents of the AML Program and make any modifications prior to this being published.

2. Reviewing and Editing the AML Program

The first time that the process is followed the user is directed through this in a sequential manner and must complete the previous steps before progressing forward.

In the review step, the user can "jump" back to any section of the assessment, click the Edit button, and modify the answers.

To return to the Review mode, click on the 'Return' icon () at the top right corner.

Additional Resources on the Review & Publish section:

Additional resources and functions are available at the top right of the page:

ML/TF Risk Assessment Methodology - accessible by clicking the Methodology button () at the top right corner. This is a document that explains how the AML Accelerate methodology works.  Our experts have developed this methodology based on performing numerous ML/TF Risk Assessments across different geographies and sectors and extensive industry consultation with regulators and independent experts.

Audit Trail - accessible by clicking the Audit button ().

This pop-up provides your team with a record of any actions and changes made throughout the program during its creation.

PDF Reports - Download drafts of the program documents in PDF by clicking the relevant PDF button.

1. ML/TF Risk Assessment PDF

2. AML Policy PDF

3. CDD Standards PDF

4. Appendices PDF

5. 'Full' includes the risk assessment, AML policy, and CDD standards

6. Action Plan PDF

Ratings CSV - Download the program ratings in CSV format by clicking the CSV button ().

3. Review the Action plan

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.

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 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.

4. Publishing the AML Program

Once the user has completed the review and is satisfied that all of the required changes and edits have been made they can formally Publish the AML Program, which commits all of the artifacts to the AML Program Manual - Audit History page.

To publish (finalise) the program click the Publish button.

Prior to publishing the AML Program and the related contents, there is a warning and attestation message for the user to confirm that they have read and understood the contents of the documents.

Once published the online version of the report is displayed and can be downloaded using the PDF icon on the top right-hand side of the screen.

Important:

Once an AML Program has been published, it is NOT possible to unpublish it or make further edits. To 'make changes', the user must create a new AML Program and prefill from (copy) a previous AML Program.

The regulated entity must ensure that they are fully in agreement with ALL of the content within the AML Program, as regulators will expect regulated entities to provide evidence of these documents having been drafted, reviewed, published, and formally adopted by the regulated entities governing body.

5. AML Program Manual - Audit History

After the user has published the AML Program Manual, the Audit History page (Home page) is automatically updated with the publish date.  In the action column, a series of icons direct the user to the downloadable PDF versions of the documents. These can be downloaded individually or collectively.

Note: File attachments in your program will appear in the PDFs as hyperlinks. Selecting the attachment hyperlink in the PDF will download the attachment if the user is logged into AML Accelerate.

At this point, whilst the AML Program Manual has been created, it has not yet been formally adopted by the regulated entities governing body, which is a mandated step in most countries' AML laws and regulations.

6. Adopting the AML Program Manual

On the Audit History page, alongside any published AML Program Manuals, there is an Adopt button which is designed to demonstrate that the organisation's governing body has formally adopted the AML Program Manual and evidenced by appropriate documentation, for example, Board meeting minutes.

Once the Adopt button is selected, the following pop-up box appears where the user can confirm that the AML Program Manual has been adopted by selecting the checkbox and uploading any supporting evidence.

After the supporting evidence has been uploaded the document will be stored in the system and is accessible in the audit history.

The Audit History page below shows where an AML Program Manual has been formally adopted, which is date stamped with the supporting evidence document able to be downloaded from the main dashboard.