Companies carrying out relevant financial business or relevant activity under the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR) are identified as Subject Persons, required to implement effective internal control systems in order to fulfil their legal obligations in this regard.
The Risk Evaluation Questionnaires (REQs) submitted through the FIAU's Compliance and Supervision Platform for Assessing Risk (CASPAR) is the Unit's advanced monitoring system, utilised to assess regulatory compliance performance of subject persons. The automated risk scoring applied through this self-assessment platform, provides the FIAU with a deep insight into the health status of the Subject Person's internal control systems and overall exposure to risk.
Given the current challenges posed by the COVID-19 virus the FIAU has taken note and is supporting subjected persons by postponing the submission deadline to the 4th of May 2020. However, this has removed the late submission period and penalties will now start being incurred from the following day.
CSB Group's Compliance Team assists clients with their FIAU reporting requirements by focusing on the nature of the relevant activity being carried out and the context within which the subject person operates. For the Business Risk Assessment, a tailormade evaluation of all relevant business risk areas faced by the company is prepared and clearly presented for the board to be informed and deliberate accordingly, before approval and submission to the FIAU.
An REQ requires the person completing it to have intimate knowledge and access to all areas of the subject person's business. CSB's Compliance Team supports employees of subject persons tasked with the duty of collating the large volume of information in order to complete the REQ, by reviewing it before submission and providing clarity when and as may be needed.
CSB Group's AML/CFT Services are further complemented by other compliance related services such as:
- designing and implementing compliance monitoring programmes;
- drafting customised policies, manuals and procedures in line with regulations;
- conducting investigations into regulatory or compliance breaches;
- reviewing and assessing policies, manuals and procedures according to regulatory changes;
- supporting with the anticipation of compliance impacts of regulatory change;
- assisting and providing tailor-made training solutions in universal compliance topics, such as AML/CFT and GDPR
- assisting with the preparation for and response to regulatory onsite inspections and drafting an action plan in this regard;
- conducting client-specific or business-wide compliance reviews
- supporting organisations with the drafting of Business Risk Assessments.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.