Goodbye to 2020 and Hello 2021
Welcome to the 2021 MWC Blog.
MWC are back from our well-earned Christmas and New year’s break with our batteries re-charged and ready for the year ahead. We hope you managed to take some time off and enjoy with family and friends. We are certainly excited about the year ahead and are looking forward to achieving a balance between our virtual world and face to face interaction and collaboration with you.
We hope that you are just as excited as we are and well into your AML/CTF annual planning mode. If you haven’t started yet though – it’s not too late! Have you already decided what actions you should be putting in place for the year ahead? Did you manage to get some time to review our AML/CTF planning material before the Christmas break? If not, it is time to grab a cup of tea and start a plan, re-cap and review to consider the following:
- Schedule your annual review of your Program and ML/TF Risk Assessment – make sure it considers any new typologies, sector risk assessment and insights from recent enforcement actions.
- Plan your transaction monitoring rule review – if you are making changes to improve or decommission rules make sure the reasons are documented and signed off by the appropriate manager.
- Schedule your Independent Review if you are due one – make sure you are engaging right person and verify their independence (that is if we are not able to do it of course!)
- Consider your resourcing capability, have you had long term vacancies that need filling, are your resources sufficient to manage your AML/CTF risks for the up-and-coming year? Do you need to get external assistance?
- Do you have any outstanding risks that need to be addressed as a priority? Are they tracked and managed appropriately? Map them out and ensure you have captured any changes in ML/TF risk over the past year, especially with COVID 19.
- Update and schedule your training including role-based training – do not just rehash last year’s training slides. Financial crime is always evolving, remember, criminals, are often always one step ahead. Consider whether your Board requires a specific education session to allow them to discharge their own obligations – did you know we have a great training session specifically for Director training?
- Schedule regular reviews, oversight, and assurance activities. Plan key control testing to ensure controls are operating efficiently and effectively to manage internal weaknesses and areas of vulnerability.
Remember! If you have you identified any additions to the above list including any priorities that you might require assistance with, let us know and we can schedule a specific workshop through your compliance counsel membership.
We hope that you had a great Christmas and New Year, we are very much looking forward to seeing you soon! In the meantime, please don’t hesitate to reach out if you have any questions.