Mike Jardine, who became an AML inspector in 2018 recently presented How to Prepare for an AML Inspection - An Inspectors Perspective. In this webinar, Mike imparted his expert insights into what not to do when you’re preparing for your AML inspection.
1. Ignoring AML Obligations: Compliance with AML legislation and professional body supervisor requirements is not optional. Ignoring these obligations can lead to severe consequences, including loss of clients, damage to your reputation, and hefty fines. It's essential to stay on top of these responsibilities and ensure that they become part of your daily, weekly, and monthly activities.
2. Falsifying Documents: Never backdate documents or falsify information. This is worse than not having the document in the first place. Inspectors can easily identify falsified documents, which can lead to serious repercussions, including fines and damage to your reputation.
3. Using Templated Documents Without Customisation: While templated documents can be helpful, it's crucial to tailor them to your business. Using generic risk assessments or compliance procedures without customization can lead to inconsistencies and inaccuracies, which inspectors will quickly spot.
4. Delaying or Procrastinating: If you've been given a timeframe to complete something, do your best to meet it. Employing delaying tactics or constantly seeking extensions can raise red flags. If you genuinely need more time, communicate this to the inspector promptly and provide a valid reason.
5. Not Keeping Up-to-Date Records: Even if a client ceased to be a client years ago, you should keep their due diligence records for at least five years. Law enforcement or inspectors may ask to see these records, and not having them can lead to complications.
6. Not Adapting to Changes: If something changes with your client or your firm, update your risk assessment and compliance policy immediately. Don't wait for your annual review. Show that you're proactive and that compliance is at the forefront of your mind.
7. Not Asking for Help When Needed: If you're unsure about your AML obligations or need help with compliance, don't hesitate to ask for assistance. It's better to seek help than to make mistakes that could have been avoided.
Remember, the main goal of AML regulations is to detect and prevent financial crime and fraud. By staying compliant, you're not only protecting your business and reputation but also contributing to the fight against financial crime.
To watch the full session by Mike Jardine, just click here. In the session, Mike covers the above as well as:
- Why me?
- What to do when you get the call?
- The compliance culture
- Do's and Don'ts
- Case study - Consequences of getting it wrong
The contents of this article are meant as a guide only and are not a substitute for professional advice. The author/s accept no responsibility for any action taken, or refrained from, as a result of the material contained in this document. Specific advice should be obtained before acting or refraining from acting, in connection with the matters dealt with in this article.