In Chapter 10.12, Compliance Management, IPPC and Independent Audit, First Edition, Money Laundering – A Handbook for CDD Compliance enlighten the objective of compliance management with the aid of CSP Compliance Management Diagram 31.
In Anti-Money Laundering (“AML”) language, an organisation such as a financial institution, a DNFBP, a public company or even a private company participating in the fight against money laundering requires:
· A set of AML Operation Manual or AML Policy
· Ongoing Compliance Program
· Compliance Officer
In a layman language, a captain of a ship could not sail without a compass or a navigator to assist him. Applying this principle, the Compliance Officer who is responsible for the day-to-day AML/CFT compliance is unlikely to achieve “Complaint” with an old compliance program, untested AML/CFT Policy or even without an AML/CFT Operation Manual. Ignorance on AML/CFT compliance management gives rise to penalties or possibly with a grade down to “Non-Compliance”.
Today, the majority of the FATF members have their AML/CFT laws and regulations embedded with a necessity to have an independent audit on the Internal Policies, Procedures and Controls (“IPPC”) to ensure that AML/CFT systems and policies are adequate to combat money laundering.
There are costs for compliance and it may be a concern to small DNFBPs, for example, corporate service providers, accounting firms, law firms, and trust service providers may be self-employed or with two or three partners providing the services. The IPPC audit fees vary according to audit assessment of the activity and structure of the organisation. No two firms are the same. It is the “risk” that matters.
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Categories: UNODC, UNCAC, FATF, AML/CFT Compliance, Money Laundering, Risk Assessment, AML/CFT Audit Assessment