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Increasing the Need for AML Maturity Assessments


Late last month, Europe’s ever-growing money laundering crisis took a new turn - Dutch lender, ABN AMRO, disclosed a criminal probe over alleged failures to check on clients and report suspicious transactions. The Dutch probe adds to a series of money laundering cases that have inundated lenders, particularly in Europe, which highlights weaknesses in the region’s efforts to fight the flow of illicit funds [1].


ABN Amro is under investigation for failing to report suspicious transactions and not conducting enough due diligence on its clients. Following the €775m ING fine last year and the central bank’s criticism, the largest Dutch banks have been stepping up compliance spending, including increasing headcount to its financial crime prevention teams and carrying out anti-money laundering (AML) internal reviews, such as AML maturity assessments.


Specifically, the premise of the latter is for firms to assess their internal AML competencies, whilst recognising their possible failing to policies and procedures. Often this involves key stakeholders from the board level down, to understand, assess and review the financial crime compliance framework currently in place.


More specifically this would involve:

  • Review of Board-level Governance;

  • Review of Governance Framework with a specific focus on AML controls;

  • Review of current policies and procedures; and

  • Regulatory rules mapping of the institutions regulatory permissions against current regulations.


The completion of AML maturity assessments also enables the facilitation of peer benchmarking, for firms alike to ‘bench’ their AML efforts against firms alike. If for example, the AML process is understanding at a coherent level, such as risk decisions are based on the implement policies of the firm, they are transparent and have completed in-depth analysis to come to their decisions, it can be assumed that there is a solid cultural adoption of such internal policies. In short, this means a firm is likely to have good compliance outcomes. Alternatively, if the AML process has large gaps, this is likely to lead to poor risk management and little adoption of internal controls.


How Can Lysis Help?


The Lysis AML Maturity Assessment is a review and assessment of a firm’s current AML framework and governance program. The Maturity Assessment will identify any regulatory gaps or areas of concern which the firm should take remedial steps to enhance. The assessment is done in line with the current industry regulations and best practices against the firm’s business model and risk appetite. Upon completion of the Maturity Assessment a detailed plan will be provided advising the next steps the firm should take in order to meet the regulatory requirements. The Lysis AML Maturity Assessment can be tailored to meet the specific requirements of any firm, regardless of business activity and industry.


Following a health check, Lysis can then assist with:


  • A change programme to enhance the AML Framework, Policy, Procedures and Systems AML;

  • Remediation of customer files and transaction monitoring records; and

  • Training workshops to ensure all staff are aware of their responsibilities regarding AML and have the necessary skills to carry out those roles.

For more information please contact info@lysisfinancial.com


[1] https://www.independent.co.uk/news/business/news/abn-amro-money-laundering-investigation-danske-bank-latest-a9121066.html


By Lauren Parmenter, Consultant at Lysis Group

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