Have You Completed Your AML Audit? Time is Running Out

Why AML/ATF Annual Reviews Are Important

AML/ATF-regulated entities in Bermuda have an obligation of having an independent Anti-Money Laundering (“AML”) audit performed at least annually. This means at least once a year and more frequently when senior management becomes aware of any gap or weakness in the AML/ATF policies, procedures or controls, or when senior management deems it necessary due to the RFI’s assessment of the risks it faces” (BMA Guidance 1.75).  Firms should complete the audit for 2018 by end of year 2019.  If you haven’t completed your audit yet, time is running out.

It’s Required: Not only is an annual AML audit mandatory in all regulated sectors, it is a key part of your annual review of your AML/ATF Programme. Regulators continue to closely scrutinise organisations and how they define, implement and maintain their AML platform.

Protection : Successful companies have reputations built on trust and transparency.  A strong Anti-Money Laundering and Anti-Terrorist Financing (“AML/ATF”) Programme together with an experienced Money Laundering Reporting Officer are vital to protecting you and your firm from fraud.

What Will an Independent AML/ATF Auditor Do?

When conducting an independent AML/ATF audit, the auditor should evaluate:

  • the risk rating assigned by the company under review and consider its appropriateness to the company’s business model and size
  • management’s ability to document its risk assessment process and clearly articulate how it aligns with Bermuda’s National Risk Assessment Report
  • the company’s maintenance of a risk register which identifies the risk score for each account and highlights where additional monitoring is required for high risk clients.
  • A company’s culture and its commitment to training and awareness of the regulatory landscape governing AML/ATF within its licensed activities
  • the adequacy of the company’s AML/ATF policies, procedures and controls and the business’s regulatory compliance with legislation.
  • how aligned the company’s practices are with its stated policies, procedures and controls

Oyster Consulting’s professional support can help you assess and improve your firm’s AML programme.  Oyster has a highly experienced team. Our consultants have conducted AML audits across all industries, so we know what it takes to get the best end result.


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