preview

Internal Management Information And Controls For Financial Crime

Better Essays
Open Document

Part 1

Further to my review of internal Management Information, produced in relation to our Anti Money Laundering procedures, it is apparent that immediate action is required to contain a possible failure of our systems and controls.

I will list who I will liaise with, giving reasons why.

1. A paper will be circulated to the Board noting my intention to investigate our systems and controls for financial crime (including AML), the provision of AML MI and the identification and mitigation of AML risk. This is an immediate priority as the Board need to be adequately warned of any potentially significant issues to ensure good governance is demonstrated. This note would not, at this stage, be able to provide a quantum but would indicate …show more content…

3. In order to understand the severity of each risk I would undertake a risk assessment, rating each risk according to the severity of the potential consequences of the uncontrolled crystallisation of each risk. Audit and Risk teams would be engaged to ensure an appropriate review of the end to end risk process in accordance with documented processes. I will use the following risk matrix. It is important to note that the initial view of each risk may change following more detailed investigation.

IMPACT 3 (HIGH) LOW MEDIUM HIGH 2 (MEDIUM) LOW MEDIUM MEDIUM 1 (LOW) LOW LOW LOW 1 (LOW) 2 (MEDIUM) 3 (HIGH) LIKELIHOOD

4. A Compliance report containing an Executive summary accompanied by detailed findings would be circulated. This report would identify key stakeholders with whom I would engage to ensure a clear understanding of the risks. This document would underpin an action plan to identify, quantify and remediate identified issues. It would ensure a considered approach to the issues at hand.

5. The report would review our current systems and controls against desired systems and controls, reporting on any shortcomings or gaps. It would contain an assessment of each key issue, subsequent high level action and those required to be consulted:

ISSUE (HIGH RISK): ML and other MI is not submitted in a timely

Get Access
Related
Get Access