FD11.04 - Identify reporting entities requiring further verification

Description	Identification of reporting entities selects entities with high compliance risk for closer verification
Example Work Products	FD11.04.01 – Compliance risk assessment model FD11.04.02 - Reporting entities not submitting reports FD11.04.03 - Reporting entities not submitting reports within the due date FD11.04.04 - Reporting entities submitting reports with data quality errors FD11.04.05 - Reporting entities not taking steps to rectify defects in report FD11.04.06 - Reporting entities where the share of reports submitted by the sector is substantially lower as compared to their market share FD11.04.07 - Reporting entities submitting limited type of suspicion in the STRs
Notes	FIU may implement a risk based compliance approach using a rule based system to select reporting entities for further verification

FD11.05 – Conduct compliance verification

Description	Verification of compliance and assessment of adequacy of internal controls identifies areas of non compliance.
Example Work Products	FD11.05.01 - Assessment of adequacy of AML policies, procedures, and processes to ensure compliance with applicable laws and regulations FD11.05.02 - Assessment of awareness level of the board of directors and senior management about AML regulatory requirements FD11.05.03 - Verification of adequacy and accuracy of communication of policies, procedures, and processes to employees. FD11.05.04 - Assessment of the resource availability and competence of staff the compliance department FD11.05.05 - Assessment of adequacy of process to conduct risk assessment of products, services, customers, entities, and geographic locations. FD11.05.06 - Assessment of adequacy of internal controls to address high risk products, services, customers, entities, and geographic locations. FD11.05.07 - Assessment of adequacy of customer identification and verification procedures FD11.05.08 - Assessment of adequacy of record keeping procedures FD11.05.09 - Assessment of adequacy of alert generation system FD11.05.10 - Assessment of adequacy of alert review system FD11.05.11 - Assessment of adequacy of report preparation process FD11.05.12 - Gap analysis between the transactions to be reported and actually reported FD11.05.13 - Assessment of adequacy of transaction monitoring system FD11.05.14 - Assessment of adequacy of watch list screening system FD11.05.15 - Assessment of adequacy of detecting transactions matching with ML/TF typology FD11.05.16 - Assessment of adequacy of risk management system FD11.05.17 - Assessment of adequacy and timeliness of training for compliance staff, front line staff, compliance unit, relationship managers, senior management and board. FD11.05.18 - Assessment of adequacy of internal audit and compliance functions in evaluating and ensuring adherence to the AML policies and procedures FD11.05.19 - Assessment of adequacy of customer education programme FD11.05.20 - Assessment of adequacy of employee recruitment and screening process
Notes	The timing, frequency and scope of areas to be verified during inspection should be determined on the basis of AML/CFT risk posed by the institution. The combination of off-site and on-site verification/examination can be used depending on the powers of competent authorities and resource availability. FIU may use the services of supervisors or third party auditor to conduct on site examination.

Дата добавления: 2015-11-14