ANTI MONEY LAUNDERING

Preparation:

• Coordination with the Client: Scheduling the visit, identifying contact persons, requesting relevant documents.
• Document Review: Analyzing the received documents to understand the company's existing AML program.

Interviews with:

• The Management: to understand their commitment and vision regarding AML.
• Responsible Personnel: involved in the AML program processess.
• Key Functions: Interviews with personnel from various functions to understand how they apply the procedures and how processes work.

Conclusions and Reporting:

• Identification of risks and deficiencies: Identification of the deficiencies in the existing program, the risks resulting from non-implementation, and formulation of concrete recommendations for improvement.

Deliverables:

• Detailed report presenting the findings, conclusions, and necessary recommendations for designing proper and efficient processes.

Activities:

• Discussions with stakeholders to understand the internal structure, internal processes, and clientele
• Requesting supporting information to establish flows and draft documents
• Drafting documents
• Reviewing documents with stakeholders
• Implementing the changes resulting from the review

Deliverables:

• AML Policy
• KYC Procedure (B2C)
• The Procedure for Reporting to the National Office for Prevention and Combating Money Laundering (NOPCML)
• Risk Assessment Methodology (RBA, according to AML legislation)
• Internal Business Partner KYC Procedure (B2B)

 Activities:

• Coordination with the Client: Scheduling the visit, identifying contact persons, requesting relevant documents.

• Document Review: Analyzing the received documents to understand the company's existing AML program, including the Risk Assessment Methodology, if any, and how it is updated whenever necessary, both based on legislative changes/modifications and changes occurring at the company level that could impact this process.

• Analysis of previous risk assessments, if any, and how they were conducted considering specific risk factors, including those related to clients, countries or geographic areas, products, services, transactions or distribution channels, as well as how measures were initiated to mitigate significant risks.

• Obtaining the necessary source data for the risk assessment;

• Conducting the assessment itself based on the risk matrix, considering specific risk factors including those related to customers, countries or geographic areas, products, services, transactions, or distribution channels.

Interviews with:

• The Management: to understand their commitment and vision regarding AML.

• Responsible Personnel: involved in the AML program processes.

• Key Functions: Interviews with personnel from various functions to understand how they apply the procedures and how processes work.

Deliverables:

• Drafting a risk assessment report that will present the findings of the company assessment, including the rating assigned to the control environment.