You don’t need to throw the baby out with
the bathwater.
The risk based approach
assumes that there are finite resources for
compliance. You just need to make sure that
you have deployed those resources sensibly
and effectively, i.e. against areas of the
highest risk of an AML incident happening.
There is a truism, “In theory, there is no difference between theory
and practice and in practice there is”. Most people now accept the language
of the risk based approach. Unfortunately it is not so easy to translate into
practice. The benefit of an independent approach is that you are less likely
to miss what is obvious to an outsider / regulator?
AML Training and
Competence
From high impact bespoke courses to basic introductions to personal liability
under AML law OAOA can deliver what you need.
Members of the Law
Society of England and Wales or the Association
of International Accountants can be eligible for
Continuous Professional Development points. Please
contact OAOA for details.
Implementation
of risk based systems and controls
Does what it says on the tin.
Coaching and
mentoring for the Senior Management team responsible
for AML
Particularly in Partnerships there can be an assumption
that the interests of the Senior / Managing Partner,
the firm, its partners, employees and clients
and legally defined role of the MLRO will always be the same. They aren’t
and they won’t be and you need to prepare for a serious AML incident
before the firm and its MLRO comes under stress from external sources. You
need to make sure that you understand what doing the right thing is under Proceeds
of Crime Act before it becomes an issue.
AML News
SOCA enlists boardrooms to fight business -focused crime
Britain's answer to the US FBI has built up a network of more than 1,500 senior contacts in boardrooms around the country to disrupt efforts by organised criminal gangs to infiltrate or disrupt legitimate businesses.