As an AML Compliance Officer, there's a lot to manage beyond daily tasks. Policies, procedures, internal training, and much more must be revisited and documented each year.
Tasks can be distributed among different employees in a company, but the AML Compliance Officer holds the overall responsibility for ensuring they are completed. There are recurring annual tasks that must be addressed to keep your workflows and documentation in order.
Instead of letting everything pile up throughout the year, we recommend planning a few activities each month, allowing time for other tasks. Below is an overview of the tasks you need to complete so you can plan your activities for the coming year.
Your documentation package includes a risk assessment, as well as your policies, procedures, and controls — as required by Sections 7 and 8 of the AML Act. These documents must always reflect your company's current profile, so you need to regularly consider internal and external factors that may affect your existing documentation.
If changes occur in your business model, such as the introduction of new client types or services, you must update your risk assessment and review your policies and procedures to address any inherent risks.
Even if there are no changes to your company's profile during the year, you must revisit your risk assessment annually. It must always be aligned with current facts and any legislative or regulatory changes, such as updates from the latest directive or national risk assessments.
You can read our guide on completing your company's risk assessment here, and tips for completing your policies, procedures, and controls here.
It's essential to maintain accurate information about both new and existing customers. Throughout the year, your KYC procedure should ensure that you complete this task every time you onboard a customer.
Annually, it's a good idea to ensure you've followed the procedure for all customers and that it complies with current legislation. This helps ensure you continue to collect and validate information correctly.
Internal control is crucial to ensure that your procedures for preventing money laundering work as intended. It's not just about checking compliance with regulations but also identifying opportunities for improvement and minimising risks.
Your internal controls may involve stress checking KYC procedures and thoroughly reviewing your documentation.
Additionally, remember that your internal controls must be documented — specifying what was controlled, which methods were used, and what results were achieved.
Training is a legal requirement to ensure that you and your colleagues stay sharp on AML regulations. It’s also a valuable investment in your overall compliance efforts.
You can conduct training yourself based on specific cases or seek assistance from an external resource. Our Consultancy Services offer training in AML legislation, always up-to-date with relevant topics and inspiring case studies.
Although not a legal requirement under the AML Act, conducting an annual evaluation is highly beneficial. What works well? Where is there room for improvement? Should you explore new ways to streamline your work in the coming year?
The annual evaluation of your efforts also helps determine whether your planned activities are sufficient to ensure AML compliance throughout the year.
Is your compliance calendar ready? If not, there's no better time than now to get started.