AML Audit

AML/ATF-regulated entities in Bermuda have an obligation of having an independent Anti-Money Laundering (“AML”) audit performed at least annually. Oyster will compare your firm’s written policies and procedures, actual practices, books and records, and controls against AML/ATF requirements and regulations by testing records using risk-based and random sampling methods.

Included in an Oyster AML Audit is the review of:

  • AML/ATF Program Structure, Approval and Oversight
  • Customer Identification / Onboarding Program
  • Financial Intelligence Agency Section 16 Requests
  • Review of Accounts, with an emphasis on High Risk Accounts
  • Transaction Monitoring
  • Sanctions Screening
  • Suspicious Activity Reporting and Consent Requests
  • Training and Education

The Oyster Difference

Oyster’s consultants, having themselves been Chief Compliance Officers, compliance officers, and Money Laundering Reporting Officers, have been subject to 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.