Anti-Money Laundering (AML)*
As corruption, terrorism and crime in general increases, so too does the need for criminals to launder the proceeds of their illicit activities. The result of this is increased focus and pressure from the international community as well as regulators to combat the scourge. In response to the Financial Action Task Force (FATF) 40+9 recommendations many countries have implemented strict AML and Counter Terror Financing (CTF) Laws. These laws most often require the establishment of a Financial Intelligence Unit (FIU)** and places obligations on accountable institutions to implement AML Programs and Policies to assist in properly identifying parties to business relationships and reporting suspicious activities to the FIU. South Africa and other countries in Africa are no exception.
Our diverse team of professionals at Deloitte Risk Advisory has experience in Data
Analytics, Audit, Legal, Forensics, Compliance and Risk. We work with employees in our Global AML practice, who have over 20 years of experience in designing, reviewing, enhancing, implementing and monitoring numerous anti-money laundering detection and compliance programs for clients around the world.
We are therefore in a unique position to assist institutions to adopt international best practice by:
- Interpreting legal provisions,
- Assessing AML risk in the organisation,
- Conducting internal control assessments,
- Conducting due diligence on clients and vendors,
- Drafting and enhancing policies and procedures, including group standards for multiple jurisdictional entities covering the important elements of a robust
AML Compliance program which includes but is not limited to:
- The appointment of an Anti-Money Laundering Compliance Officer (AMLCO)***
- Know Your Client (KYC) procedures at account opening and transactional levels
- Account and transaction monitoring
- Reporting of suspicious activity or suspected terror related activity to a FIU
- Keeping records of accounts, transactions and reports made to the FIU
- Initial and ongoing training for key individuals
- Assessing internal business systems and processes to ensure client information is appropriately captured, stored, analysed and otherwise utilised by accountable institutions,
- Assessing sanctions risks and designing and implementing appropriate sanctions policies,
- Assessing, selecting and assisting with the implementation of appropriate technology suppliers and solutions to ensure regulatory obligations are sufficiently discharged,
- Reviewing and evaluating system rule and effectiveness in new and existing technology solutions,
- Providing an independent assurance function on AML Programs,
- Assisting accountable institutions to prepare for supervisory inspections,
- Providing specialist AML employee placement,
- Designing and implementing training for all employees including the AMLCO, Executives and members of internal audit, compliance, investigation and analysis units to ensure operational effectiveness of programs.
A range of products, which have been developed by highly knowledgeable and skilled employees from member firms around the world, are available for deployment in support of our clients’ efforts to remain compliant.
Deloitte is also in a position to:
- Consult with and assist supervisory bodies with AML inspections,
- Consult on the drafting of new appropriately suitable AML laws or amendment of existing laws based on country profiles and jurisdictional needs,
- Consult with industry and regulators on the drafting of subordinate legislation such as regulations and guidance notes to the AML laws,
- Consult on the establishment of local Financial Intelligence Units,
- Provide investigative training and support to law enforcement entities for successful investigation of money laundering cases.
*Also referred to as Money Laundering Control (MLC)
**Also referred to as a Financial Intelligence Centre (FIC)
***Also referred to as a Money Laundering Control Officer (MLCO) or Money Laundering Reporting Officer (MLRO)