Anti-Money Laundering (“AML”)/Anti-Terrorist Financing (“ATF”) regulated entities in Bermuda are obligated to have an independent AML audit performed at least annually, and must appoint an experienced AML/ATF Money Laundering Reporting Officer (“MLRO”) to comply with the AML/ATF regulations set forth in the code of conduct. In addition, Insurance Managers must have procedures in place to conduct proper due diligence and prevent fraud. Oyster will compare your firm’s written policies and procedures, actual practices, books and records, and controls against AML/ATF requirements, and can provide outsourced MLRO services and AML/ATF training for your firm.
Included in an Oyster AML Audit is the review of:
- AML/ATF Program Structure, Approval and Oversight
- Financial Intelligence Agency Section 16 Requests
- Review of Accounts, with an emphasis on High Risk Accounts
- Suspicious Activity Reporting and Consent Requests
Outsourced Money Laundering Reporting Officer
An Oyster MLRO can complete the following tasks:
- Registration of your entity with the Financial Intelligence Agency on Go AML
- Review of unusual activity and filing Suspicious Activity Reports (“SARs”)
- Reporting to senior management and the Board of Directors to identify SAR trends
- Development of training programs for staff awareness of AML/ATF standards
The Oyster Difference
Oyster’s consultants, having themselves been Chief Compliance Officers and Money Laundering Reporting Officers, have conducted AML audits and know what it’s like to sit in your seat. We will work with your team to make sure our assessment is fair and accurate. Prior to issuing a final report, we will prepare a draft report for discussion, identifying efficient and practical ways to close gaps and achieve best practices. Oyster has worked with many different types of regulated clients, small to large, with a variety of different business models. Additionally, Oyster offers discounts to our clients who sign up for multiple audits.