Maestro-Solutions for

Anti-Money Laundering


AML/CTF & Sanctions, probably the biggest risks in Financial Services!

The prevention of money laundering and terrorist financing has united the financial regulators in taking firm and resolute action.

Firms have been shut down because of poor Anti-Money Laundering (AML) management while the fines have escalated to a level where they can exceed profits.

Our AML Governance solution enables clients to protect their business by evidencing compliance with the regulatory requirements:

  1. Management Body Oversight: Ensure that Senior Management have thorough control over AML
  2. Resources/Expertise: Show regulators that the firm has dedicated sufficient resources to AML (personnel, systems, data, etc.)
  3. Size/Complexity: Assess the AML framework (policies/procedures/controls) based on the size and complexity of the firm
  4. Monitoring/Reporting: Show that the firm’s AML policies, procedures and controls are monitored, results are reported and actions taken

GRC-Maestro keeps the records you need to show: the who, what, when and why regarding AML Governance.

The first step in building an AML regime that is fit for purpose is to undertake a comprehensive AML Risk Assessment.

Knowing your AML risks is essential because your whole AML regime is built on the AML risks that your firm faces.

Our AML Risk Assessment solution enables clients to protect their business by evidencing their AML analysis and shows regulators that the whole AML regime is built on a solid base, including:

  1. Policies and Procedures: Ensure that AML policies and procedures are complete and up-to-date
  2. Training: Record the training requirements of Directors, Senior Managers, AML Officers, etc.
  3. Products and Services: Assess the AML risk posed by the firm’s product mix
  4. Firm Level Assessment: Determine the firm’s AML risk level
  5. Sanctions and PEPs: Record the firm’s approach to Sanctions Monitoring and PEPs

GRC-Maestro keeps the records you need to show: the who, what, when and why regarding your AML Risk Assessment.

After undertaking an AML Risk Assessment and implemented AML Governance your firm needs to ensure that the AML policies and procedures have been implemented and are working as specified.

AML Monitoring must be conducted on a scheduled and repeating basis at a frequency determined by the risk. At the very least, AML monitoring has to be annually.

AML Monitoring has to be formally executed and the results reported. Regulators usually specify key areas that the AML Monitoring should cover, including:

  1. AML deficiencies: List all material deficiencies identified by monitoring in the current period or open at the end of the last monitoring period, including a description of actions taken/being taken to resolve them
  2. Internal controls: The success or failure of current internal processes, systems and controls in preventing or identifying money laundering over the period
  3. Resourcing: An assessment of the adequacy or otherwise of existing AML resources (staffing, systems, data, etc.)
  4. Suspicious transactions: The number of internal suspicious transaction reports and those which were investigated and subsequently reported to the national AML agency

GRC-Maestro keeps the records you need to show the AML Monitoring performed, issues flagged and resolutions implemented.

The FATF Guidance on Correspondent Banking Services details recommendations for minimizing the AML/Sanctions risk from Correspondent Banks.

Banks are responsible for ensuring their Correspondent Banks have comprehensive AML/Sanctions procedures and have implemented them. As part of the management of Correspondent Banks, a bank must:

  1. Business profile – Gather information on their Correspondent Bank’s business
  2. AML/Sanctions Controls – Assess the adequacy and implementation of Correspondent Bank’s AML/Sanctions controls
  3. Account Opening – Obtain Senior Management written approval for all new Correspondent Banks
  4. AML/Sanctions Responsibilities – Document and have written confirmation of the responsibilities for AML/Sanctions between the bank and their Correspondent

Correspondent Bank relationships have to be periodically reassessed and the information initially collected as to be updated and reassessed.

GRC-Maestro keeps the records you need to show: the who, what, when and why regarding Correspondent Banks AML/Sanctions management.


Regulatory Jurisdictions

AML Governance

Regulators require firms to draft and implement detailed policies, procedures…

AML Monitoring

Regulators expect firm to ensure their procedures and controls to…

AML Risk Evaluation

Regulators require firms to undertake a periodic AML Risk Evaluation to…

AML/Sanctions: Correspondent Banks

The FATF/Wolfsberg have detailed checks on Correspondents…