Writing a report from Compliance Head to Risk Committee which outlines concerns and suggests enhanced measures designed to safeguard the firm.
After conducting a review of the firm’s AML/CFT policies, procedures and culture. Your initial observations are as follows:
i) The volume of suspicious activity reports (SARs) sent from the firm to the financial intelligence unit (FIU) are below your expectations, given the nature, size and type of business activities of the firm. You note that the FIU have commented about the lack of information and quality of many of the SARs.
ii) There was a general lack of awareness among many of the business divisions of the firm relating to:
• the importance of identifying potential cases of money laundering
• knowledge around what constitutes ‘suspicious’ activity within the business
• how to report any concerns around unusual activity
• the significance of undertaking customer due diligence (CDD) when on- boarding new clients and on an ongoing basis
• a lack of interest and concern from senior management around the risk of financial crime to the firm.
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