Our full AML/CFT compliance services include but are not limited to the following:
Drafting of the Business Risk Assessment (BRA)
Subjects Persons need to understand and assess the risks that their business is exposed to and assesses the likelihood and impact of ML/FT risks. Depending on the type of business one is running, this will have different types of threats and vulnerabilities which need to be pointed out in this BRA both from a qualitative and a quantitative point of view. The BRA should include a description of the business, identification of risks, analysis of the risk model and mitigation techniques that are applied, risk calculations, recommendations, and conclusions. 3SIXTY Core Consultants’ services can assist you with building your own BRA and keeping it up to date as it must be reviewed at least annually.
Drafting of the Customer Risk Assessment (CRA)
Subject Persons need to identify the AML risk model on customers, which is ultimately a calculation based on four main pillars, such as the product, service and transaction risk, the customer risk, the jurisdiction risk and the delivery channel. The CRA needs to be designed in line with the AML/CFT obligations and the level of detail is to reflect the complexity of the business relationship or occasional transaction to be entered into. 3SIXTY Core Consultants can assist you with building your own CRA.
Drafting the Country Risk Assessment
Subject Persons are required to establish the risk of the countries and assess whether the jurisdictions they work with through their customers are non-reputable jurisdictions or are otherwise to be regarded as high-risk jurisdictions. Through a deep analysis, one is to consider any accreditation, declaration, public statement, or report issued by an international organisation which lays down internationally accepted standards for the prevention of ML/FT. The list of sources that subject persons are required to take into consideration are the Financial Action Task Force (FAFT) Public Documents, the Commission Delegation Regulation (EU) identifying high-risk 3rd countries with strategic deficiencies and the Statements and/or Declarations issued by the FATF or by the FSRB. 3SIXTY Core Consultants can assist you with building your own Country Risk Assessment.
Drafting the AML/CFT Manual
The AML/CFT manual is also another essential part of the AML/CFT internal documentation. The aim of this manual is to set out the rules to be observed by the subject person to comply with the AML/CFT regulations. This tailor-made manual must contain internal AML/CFT company policies and procedures, including the policy on Reputable and Non-reputable jurisdictions, client acceptance policies, client risk classification, client risk assessment, onboarding procedures, ongoing monitoring procedures, staff training information, record keeping and reporting procedures (internal and external). 3SIXTY Core Consultants’ services can assist you with building your own AML manual.
Drafting of the KYC Onboarding Document
Knowing your customer is one of the fundamentals of the business in terms of compliance. The drafting of Know Your Client (KYC) onboarding document will be built according to the type of your business and the business risk, to obtain the right information and right documentation for your clients’ files. 3SIXTY Core Consultants can assist you with building this KYC onboarding document.
Staff Training in relation to AML/CFT Rules
It’s important that all your employees are knowledgeable with the AML/CFT rules and policies. Training sessions can be held by the 3SIXTY Core Consultants experts at your premises or online through presentations ensuring to cover internal policies, reporting procedures and other essential compliance rules related to your specific business.
Assistance with the Annual Filing of the REQ
The Risk Evaluation Questionnaire (REQ) is an annual submission normally held in April through the Compliance and Supervision Platform for Assessing Risk (CASPAR) portal. Each Subject Person has an obligation to complete the REQ within stipulated deadlines issued by the FIAU. This questionnaire is required to establish the AML/CFT risk of your business and to ensure that your business is following all its AML/CFT obligations. Our team, 3SIXTY Core Consultants, can assist you with the REQ filing.
AML Compliance Outsourcing
The AML compliance outsourcing function provides your business with services to perform tasks on your behalf. Apart from the drafting of the BRA, CRA, Country Risk Assessment, and the AML manual, some other AML compliance outsourcing assignments that could be outsourced to 3SIXTY Core Consultants include reviewing and updating customer files, onboarding new customers, performing risk assessments, and performing due diligence functions.
Assistance with FIAU Audits and Inspections
The Financial Intelligence Analysis Unit (FIAU) performs audits and inspections to Subject Persons from time-to-time. During such visits, the FIAU will need to ensure that the Subject Person is in line with the AML/CFT obligations, so they will request a copy of the company’s policies, including the BRA, CRA, AML manual and perform random inspections on clients’ file. 3SIXTY Core Consultants can assist before, during and after the FIAU inspections.
AML Consultancy Services
The AML consultancy services will cover anything of the above services, either in a full package, or as standalone services, or simply as a review or health check of your current AML compliance situation. The 3SIXTY Core Consultants team understands and keeps abreast with all the latest information on anything AML issued by the FIAU and will be able to work hand in hand with you to ensure you and your business are fully compliant. Our team can review and update, if necessary, any of your manuals, risk assessments, test sample clients’ files, check onboarding documents and KYC documents and more.