GOVERNANCE FRAMEWORK

The level of sophistication of the internal controls should be commensurate with the size, structure, risks, and complexity of the firm.

KOMPLY prides itself with having a boutique business model enabling tailor-made service to our customers.

POLICIES & PROCEDURES

Any strategy for protecting a business against exposure to money laundering or terrorism financing begins with the formulation and adoption of an AML/CFT and Sanctions policy. This policy serves as a clear user-friendly statement of corporate intent that can be communicated internally to employees at all levels and externally to customers, regulatory authorities and law enforcement bodies. Such policies serve as a valuable indicator of effective corporate governance.

Policies and corresponding procedures are expected to be documented and regularly updated.

KOMPLY can support Subject Persons in calibrating policies and procedures in line with their business model and local regulations.

BUSINESS RISK ASSESSMENT

National and international regulations require firms to identify, manage and mitigate the risk of potential money laundering and terrorism financing activity that they may face, from customers, geographical area, products, services and transactions, and delivery channels.

The business risk assessment entails a determination of the Subject Person’s inherent risks, an assessment of the internal control environment, and the derivation of the residual risk. Subject Persons must then articulate the assessment into a risk assessment report, establishing resulting actions with appropriate prioritisation, which should in turn trigger a re-evaluation of the institution’s risk appetite.

KOMPLY has in-depth knowledge and experience on structuring business risk assessment methodologies and undertaking of the whole process, which is all tailor-made to the business complexity.

CUSTOMER DUE DILIGENCE

Customer Due Diligence (CDD) comprises the gathering of all relevant information about a customer’s affairs. This is the information that enables an organisation to assess the extent to which that customer exposes it to a range of risks, including the risk of involvement in money laundering. The application of CDD is required when a Subject Person enters into a business relationship or conducts an occasional transaction.

KOMPLY consultants have hands-on experience with providing compliant customer files to Subject Persons including adequate evidencing of the identification and verification of all applicants for business, the establishment of source of wealth and source of funds, and customer risk assessment. Send us an e-mail to Request a Customer Due Diligence Audit.

COMPLIANCE MONITORING & TESTING

Because of the growing importance of adequate CDD information as a fundamental building block of a sound AML/CFT and Sanctions regime, testing programmes can provide significant comfort or an early warning of problems that are arising. Sample testing of files on a random basis will provide a means of assessing whether CDD procedures meet current standards and whether the firm’s procedures are being correctly applied.

An independent review from KOMPLY helps to ensure that CDD controls are effective. Each KOMPLY customer is assigned an AML specialist who serves as an advisor through the entire assessment process.

With an unbiased, objective view of the subject person’s operations, KOMPLY specialists assess the program by gaining a deep understanding of the customer’s business model, identify gaps during on-site visits, and propose recommended improvements which are realistic to implement.

MANAGEMENT INFORMATION

A key consideration for robust risk management is what data should be extracted and aggregated to provide management information reporting. The supply of such reporting to the senior management and to the Money Laundering Reporting Officer (MLRO) about AML/CFT and Sanctions compliance risks is a prerequisite of effective corporate governance and risk management generally.

KOMPLY works with each Subject Person to identify appropriate key performance indicators and key risk indicators which support the management in its strategic decisioning.

STAFF AWARENESS & TRAINING

Awareness training plays an integral role in the establishment of a healthy compliance culture. The level of an organisation’s exposure to risk is affected by the level of staff training and staff awareness. Unless staff have a full understanding of their obligations for recognising and reporting suspicious activity and of the organisation’s policies and procedures relating to their job, there is a commensurate chance that something will be missed.

KOMPLY offers tailored and targeted training sessions that address emerging and existing topics to help participants comprehend how they can apply the theories learnt.