In its latest supervisory issues circular (#3), CIMA noted that some licensees did not adequately update their policies and procedures manuals to take into account changes to legislation and regulations.
Carrying out periodically reviews of your existing procedures against the most up to date regulatory requirements and with an updated risk assessment of your business is key to effective risk management and passing your next onsite inspection.
CIMA noted from its onsite inspections that some licensees did not carry out a regular review of their policies and procedures.
So if you haven’t had a review of your existing procedures for a few years, you’re not alone..
Once AML procedures (and board policies) have been established it’s easy to forget they need updating. And its not solely regulatory changes that need addressing either. New target markets, a change in services offered and new technology platforms that make your business more profitable or function more effectively are all examples of operational developments that can easily require a change in your procedures.
A new target market for clients can be very good for your business. But it may also require a change in your risk rating matrix if that target market is based in a country that requires some enhanced due diligence.
A simple change in services delivered can lead to potential new risks when on boarding clients and require an update to your transaction monitoring systems.
Better technology in your firm will help make everyone more productive. But it can also mean additional security risks or it may mean that procedural changes are now required to ensure that the new technology is properly incorporated into your other risk management systems.
FTS can help. Contact us for a comprehensive review and update of your AML policies and procedures.