AML Audit

We conduct AML system compliance audits.
We test every key element of the system and its compliance

with applicable regulations and issued recommendations
incl.
by the Polish Financial Supervision Authority or the GIFI

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Independent AML audit

Verify that your institution and people responsible for AML processes are properly secured against the imposition of high administrative penalties and avoiding criminal liability.

The applied audit methods are similar to those applied by the supervisory authority as part of the controls performed. Therefore, we conduct a post-implementation review of internal regulations, primarily on the basis of the submitted documentation and information obtained from the project team of the examined institution. The offer includes an audit of the compliance of the AML system (documentation, internal regulations, processes), verification with the Act on counteracting money laundering and terrorist financing and with market practice (KNF recommendations, supervisor recommendations, GIFI messages), with particular emphasis on:

Analyzes of group and internal procedures

Analyzes of processes related to the identification and verification of customer identity, including establishing remote business relationships

Analyzes of processes related to the identification of real beneficiaries

Analyzes of processes related to the identification of persons occupying exposed political positions

Analysis of the procedure for reporting transactions to the GIFI

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Workshops

Workshops conducted with the project team (and operational persons indicated by the audited Institution, who apply the amended regulations on a daily basis as part of the company's operations) will lead to confronting the business model resulting from the documentation with the practice at the Institution. On this basis, areas that require clarification within internal regulations will be identified.

The scope of the offer also includes the verification of the correctness of the risk analysis and its documentation, adjusted to the activities of the Institution, taking into account risk factors relating to customers, countries or geographic areas, products, services, transactions or delivery channels.

Report
The result of the audit will be a summary of the results of work in the form of a report containing a legal opinion containing information on the potential level of risk of non-compliance in the areas that will be audited. In addition, the report will include a comparison of the adopted solutions with the current market practice in the context of the AML Act. This scope also includes providing recommendations for improving the AML system as part of the issues specified in the subject of the service.
AML procedure

As part of the audit, the second phase is also offered, which is focused on adjusting internal regulations to the recommendations and recommendations provided, and the possible impact of changes on related documents.

The next stage is a proposal to automate AML processes using dedicated IT tools that can be implemented by Bi Insight.

Legal grounds for conducting an audit:

Act of 30 March 2021 amending the act on counteracting money laundering and terrorist financing and some other acts (Journal of Laws of 2021, item 815)

Directive 2018/843 of 30 May 2018 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council and repealing Directive 2005/60 / EC of the European Parliament and of the Council and Commission Directive 2006/70 / EC;

Regulation of the European Parliament and of the Council (EU) 2015/847 of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/2006;

Announcements of the GIFI and the KNF Office on the application of the Act on counteracting money laundering and financing of terrorism.

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