AML & Regulatory Compliance
| S.No | Services Offered | Requirements | Key Attributes |
|---|---|---|---|
| Risk Assessments: | |||
| 1 2 3 |
AML/CFT/CPF Risks Assessment Enterprise Wide Risk Assessment (“EWRA”) GAP Assessment – FC Module & AML Policies |
Regulatory / Governance | Required by CBB Rulebook FC Module. Risk Assessment & GAP analysis are the first steps towards application of ‘Risk Based Approach’ and development of a Risk Based AML/CFT/CPF and Regulatory Compliance Plan. |
| CBB Rulebook: | |||
| 1 2 3 4 |
1. Regulatory Controls Self Assessments (“RCSA”) – Rulebook Modules 2. Controls Self Assessments – Local Laws (“CSA”) 3. Rulebook Updates – Compliance Tracking System 4. Regulatory Compliance Calendars |
Regulatory / Governance |
RCSA is developed to track ‘Actions’ on Central Bank Regulations. CSAs tabulate ‘Local Laws’ and track compliance to the local laws of the land. Ensures compliance to the Rulebook periodical updates. Ensures ‘Date Sensitive Submissions to the Regulator’. |
Regulatory & Governance Standards
Requirements
Solutions Provided by DNM
Risk Based AML & Compliance Program:
- 1. AML/CFT/CPF Risks Assessment
- 2. Enterprise Wide Risk Assessment (“EWRA”)
- 3. GAP Assessments – Policies & Procedures
Risk Assessment is the first step towards application of ‘Risk Based Approach’ and development of a Risk Based Compliance Plan ensuring implementation of a Risk Based Compliance Program.
- DNM performs AML/CFT/CPF Risk Assessments and develops Risk Based Compliance Plan meeting Regulatory Standards.
- We conduct GAP Assessments and develop, and/or, further improve Policies & Procedures ensuring that they are updated & aligned to the Regulatory Standards.
Regulatory Controls Self – Assessments (RCSA & CSA):
- 1. Regulatory Controls Self Assessments (“RCSA”)
- 2. Controls Self Assessments - Local Laws ( “CSA”)
- 3. RCSA and CSA Compliance Tracking System
- 4. Compliance Calendars
RCSA is a tool that ensures implementation of Regulatory Standards. RCSA is developed to track ‘Compliance Actions’ on Regulatory Standards. CSA tabulates ‘Local Laws’ and tracks compliance to the local laws of the land. Compliance Tracking System ensures monitoring of compliance actions.
Compliance Calendar lists all Regulatory submissions details. It is a tool that ensures ‘Date Sensitive’ Submissions to the Regulator’. It helps avoid financial penalties & bad reputation on delayed, or, nonsubmission of information to the Regulator.
- We foster Regulatory Compliance Governance Process by developing RCSAs and CSAs. (Central Bank Regulations & Local Laws).
- We facilitate implementation of RCSAs and CSAs across the organization and also conduct ‘Self-Assessment Training Programs’ which provides professional insight and confidence for performing RCSAs and CSAs effectively.
- DNM develops Compliance Calendars (Department Wise) to ensure ‘Date Sensitive’ submissions by your organization avoiding financial penalties and regulatory repugnance on delayed, or, non-submissions.
- We provide training on Compliance Calendars Controls and work with concerned staff to facilitate implementation.
Compliance Charter, Compliance Plan, Compliance Calendars & Compliance Testing:
- 1. Compliance Charter
- 2. Risk Based Compliance Plan
- 3. Compliance Testing Schedules
- 4. Compliance Reports
- 5. Compliance Issues Tracking System
- Compliance Charter defines Independence, Authority & Objectivity of Compliance Function in an organization.
- Risk Based Compliance Plan ensures compliance across the organization and tests compliance control status.
- Compliance Tracking System helps track Compliance Actions’ and progress status
- DNM develops Compliance Framework that includes Compliance Charter, Risks Assessment and develops Risk Based Compliance Plan.
- We conduct Training Programs and develop AML Analysts, Compliance Officers & Internal Auditors for effective compliance testing and reviews; for identification, documentation and reporting of AML & Compliance Risks.
Policies & Procedures:
- 1. Financial Crimes Controls Policy
- 2. AML Procedural Manual
- 3. Compliance Procedural Manual
- 4. Country Risk Policy / Sanction Policy
- 5. Customers Risk Rating Policy
- 6. GAP Assessment - Policies Implementation
Regulator requires that its licensees must develop and implement Financial Crimes Controls Policies & Procedures and exhibit effective compliance to the Regulatory Standards.
- DNM understands business universe of its clients and regulatory requirements of the jurisdiction.
- We develop Financial Crimes Policies & Procedural Manuals and Control Frameworks that are tailored to the business universe and fall in compliance to the regulatory requirements.
BoD & Senior Management Oversight:
- 1. Compliance Management Committee
- 2. Terms of References
- 3. Agenda Items
- 4. Reporting Pack & Presentation Deck
- 5. Structure of Minutes
- 6. Decisions Tracking Matrix
- Set the ‘Tone at the Top’ and exhibit ‘Oversight of the BoD’ on Compliance Governance Process & Compliance Risks across the organization.
- Monitoring of material and High Risk AML/CFT/CPF and Regulatory Compliance Issues.
- Documentation & reporting of decisions & directives of the Compliance Committee.
- Tracking of Compliance Actions.
- We design Compliance Committee’s Structure and develop Terms of References (TORs).
- We prepare reporting packs & presentation decks for BoD and provide training to the compliance staff on reporting Material / High Risk Issues to the Compliance Committee.
- We facilitate, train and develop staff on documentation, circulation and tracking timely & adequate implementation of Compliance Committee’s decisions.
AML & TMS Systems (Name Screening, Sanctions Screening & Transactions Monitoring Systems):
- 1. List Management (Sanctions & Name Screening System)
- 2. Scenarios & Thresholds (Transactions Monitoring System)
- 3. Review of Alerts Management Process
- 4. Identification, Investigation, Review & Reporting Controls
- 5. System Validation - AML & Transactions Monitoring Systems
- List Management ensures effective controls on ‘Sanction & Name Screening’ process from onboarding stage to the transactions monitoring level and across the span of customers’ relationships.
- Protects from regulatory punitive actions and financial penalties.
- Protects reputational risks.
- DNM reviews ‘List Management Controls’ and provides consultation so that you avoid Sanction’s Risks and may remain fully complied to the List Management Standards.
- Scenarios & Threshold Management Controls are critical for AML Systems, DNM designs controls on aligning Scenarios & Thresholds to the AML/CFT Risks so that you effectively monitor transactions with defined thresholds and scenarios and organization is protected from the Money Laundering Risks.
- Alerts discounting, dispensation and investigation controls are critical, DNM develops, or, further improves ‘Alerts Dispensation Controls’ to avoid Money Laundering Risks.
- DNM performs validation of AML Systems so that you remain complied to the regulatory standards.
Monitoring & Reporting Controls:
- 1. AML & Compliance Report (Monthly & Quarterly)
- 2. Monitoring of High Risk Accounts
- 3. MLRO Report (Half Yearly & Yearly)
- 4. PEP Register
- 5. High Risk Customers Profile Matrix
- 6. UBO Register
- 8. Register of Counter Parties, Vendors, Contractors
- 9. Unusual Behavior / Unusual Activity Register
- Fosters BoD’s Oversight.
- Enhances Senior Management Monitoring Controls.
- Protects licensee from regulatory actions and financial penalties.
- Ensures effective compliance governance process.
- We develop reporting structures, reporting formats, structure of MLRO Report, Registers, Matrixes and Formats for your tabulating and reporting the information in a professional manner.
- We provide training and develop relevant staff of compliance department on effective maintenance of developing and maintain controls.
Financial Crimes & Controls Training Program:
- 1. AML Training (All Staff)
- 2. Compliance Department Training (Customized)
- Development of skills in employees across organization to combat Money Laundering risks.
- Protects clients from regulatory actions, reputational damages and financial penalties.
- We conduct ‘AML & Regulatory Compliance Training Programs’ both physical and virtual that help improve and govern AML & Regulatory Compliance responsibilities in a professional manner consistent to the regulatory requirements and standards.
