Review your AML/CTF Program

MitchellSeptember 2, 2019


bronID review aml ctf program

After signing up to the bronID portal, we are able to perform an independent review on your AML/CTF program. This will provide guidance for how to update your program to the current industry best practices and how you can use the bronID portal and compliance tools to execute on your AML/CTF program.

bronID is able to help you create a new or update your existing AML/CTF Program. Check out our post, Do I need an AML/CTF Program?

When do I need to do an Independent Review?

In accordance with Section 8.6.1 of the AML/CTF Rules, Part A of an AML/CTF Program must be subject to regular independent review.

The purpose of an independent review

  • Assess the effectiveness of the Part A program having regard to your ML/TF risk;
  • Assess whether Part A of your program complies with the AML/CTF Rules;
  • Assess whether Part A of your program has been effectively implemented; and
  • Assess whether you have complied with Part A of your AML/CTF Program.

The bronID independent review will examine and/or test the following:

  • Whether Part A of your AML/CTF program is current and properly assesses that your policies and procedures are adequate to manage your money laundering/terrorism financing risks;
  • The assumptions on which the AML/CTF risk assessment was based;
  • Any changes to your money laundering/terrorism financing risk profile;
  • Any changes to your AML/CTF practices and policies;
  • How well your employees understand and comply with your program;
  • How well the business responded to previous recommendations;
  • Post-implementation reviews of how effective changes to Part A of your program were;
  • What caused any deficiencies or violations found – and your plans to rectify them;
  • Whether your AML/CTF employee training program is adequate and effective;
  • How you responded to previous recommendations;
  • Whether your compliance officer has enough seniority and authority;
  • How well your transaction monitoring systems are working in identifying suspicious matters; and
  • Whether functions you outsourced are complying with Part A of your program.

What happens after the bronID review?

If we identify that your risk assessment needs to be updated and there are changes to your money laundering or terrorist financing risk profile, you will be able to complete our online assessment forms within the portal and generate an updated risk assessment which will map easily to your new AML/CTF Program which utilises the bronID ML/TF mitigation tools and control bank.

After completing the independent review process, bronID will produce a report for the compliance officer to share with the board and senior management as the final step to completing and AML/CTF Program Independent Review process.

The report will include the suggested changes/adoption of bronID tools to combat any recognised deficiencies in the AML/CTF Program.

After completing the review process, if required, you will have the opportunity to perform a bronID AML/CTF Risk Assessment and update your program and controls to the bronID standard.

Sign up to the bronID portal and begin your AML/CTF compliance journey today!

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