Internal Management Information And Controls For Financial Crime

1125 Words Oct 3rd, 2014 5 Pages
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 that there are significant concerns. Although it may not be necessary to make a report to any regulatory body, the Board would have sufficient forewarning to consider this and to ensure an appropriate discussion with legal counsel and/or external audit.

2. Along with my Compliance team, I would review our systems and controls for managing AML to identify any significant weaknesses in the identification and mitigation of such risks. The review of systems and controls would include a desk top review of policies, procedures, reporting and assurance. This review will also include interviews with key staff engaged in financial crime operations. This would involve liaising with the operations department, IT and Quality Assurance to ensure I have…
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