When the regulators show up at the door to conduct an inspection, and ask to review your Anti-Money Laundering Program will you be ready? Through our participation in more than 100 regulatory examinations as Chief Compliance Officers, we provide expert guidance to clients through AML Reviews.
Our Anti-Money Laundering Examination team is comprised of former SEC, FINRA, CFTC and MSRB regulators, in-house compliance officers and attorneys with collectively over 275 years of experience across all asset classes and investment strategies.
We offer cost-effective solutions that are flexible and tailored to meet our clients’ specific needs.
An independent AML assessment is a required element of an AML Program. The independent assessment/audit includes an inspection of the Firm’s AML specific policies and procedures, interviews of key personnel, reviews and/or testing of processes and activities designed to uncover material gaps and/or weaknesses (if any) in the program.
Alaric’s reviews employ processes and techniques frequently encountered in AML inspections and meet the independence requirement. Alaric will assist the Firm in identifying and assessing key controls and processes, as well as risk-related activities within the Firm’s AML Program. The typical audit will cover the Firm’s AML Program for a specific calendar year but can be modified to address any 12-month period.
Alaric’s independent assessment/audit will be conducted by:
- Reviewing the Firm’s AML specific policies and procedures and related documents.
- Reviewing the prior year’s independent assessment as well as any regulatory enforcement reviews/actions.
- Interviewing the Firm’s AMLCO, discussing AML specific procedures with staff and observing the tasks in action.
- Selecting and reviewing relevant samples as applicable of certain processes with respect to key control points identified in the AML procedures and/or regulatory-related correspondence.
Areas to be included in the Scope:
- The Firm’s written AML policies and procedures.
- The AML Compliance Officer’s designation and qualifications.
- The Firm’s AML training program, including materials used.
- The Firm’s Customer Identification (“CIP”) Program.
- The Firm’s monitoring and oversight including the identification and escalation processes.
Alaric will prepare a draft summary report discussing key findings and will note material gaps and weaknesses in the program (if any), provide recommendations and revisions to enhance the Firm’s AML Program based upon the weaknesses noted citing specific rules, regulations and/or best practices (based on the Firm’s specific business activities) and where appropriate suggested revisions and updates to the Firm’s AML policies and procedures.
The findings will be discussed and reviewed, in detail, with members of the Firm’s AMLCO and/or senior management. Alaric will provide a final version of the report at the end of the engagement.
The material and information provided herein is for general informational purposes only. You should not rely upon the material and information provided herein as a basis for making any business, legal or any other decisions. Also note that actual proposals for an AML Examination Services are customized based upon the specific needs of the client at the time of the request.