AML and Fraud prevention compliance project

The scope of the project covered the development and implementation of a risk oriented approach as part of the client’s due diligence processes in order to fulfil the requirements resulting from the third EU money laundering policy and the corresponding German new anti-money laundering act, including IT technological support.

The tasks included, amongst other issues, the development of risk models, definition of parameters and risk measures setting, scoring of direct retail/corporate customers, evaluation of correspondence banking relations, pass through clients, consideration of beneficial owners, political exposed persons (PEPs) as well as case management and execution of customer due diligence processes for new / existing clients and training.

• Execution of a gap analysis (comparison of existing functional frameworks with the recently expanded regulatory requirements, resulting from the third EU money laundering policy and the resulting national requirements)
• Creation of an AML risk threat analysis
• Development of an overall target architecture in accordance with group compliance guidelines
• Concept development, realisation and implementation of a Customer Due Diligence-System
• Development of specific ‘Know Your Customer’ templates (geared towards generic customers and specific customer groups e.g. PEPs, Beneficial Owner)
• Creation and publication of guidelines / policies (including a set of risk oriented measures for customer due diligence processes)
• Consideration of local specifics (supervisory authorities) and integration of foreign Money Laundering Reporting Officer (MLRO)
• Training (concept development and training materials)
  Creation of roll-out plan

• Functional and business knowledge of processes within the AML area
• Specific understanding of market leading systems in the area of AML monitoring/research, KYC/CDD, financial sanctions/embargos, sanction and PEP-list providers
• Longstanding experience of coordinating major compliance projects