Comparing AML solutions can be scary. You might want to ask your provider some of the following questions...
You Should Be Able to Focus on Your Core Business
The provider you select should be able to give you the confidence to focus on your strengths, whilst you leave them to focus on theirs.
An expert led AML outsource company will be able to assist you with your day to day obligations as well as your long term compliance.
They should be helping you to optimise your processes, support you and your clients, whilst cutting no corners.
It is a balance - 'glittery tech' is fantastic (if it is a compliant solution), but it is essential that this has been developed with your AML and privacy obligations in mind and not only their profit margins and market share.
REMEMBER: YOU CANNOT OUTSOURCE YOUR LIABILITY
Aim to Be Cost Effective and Compliant
The support your provider gives you should be tailored to your business model. Make sure you understand what they are providing you with and the value it is providing.
Start to combat the 'fake news' in the industry and take the time to understand:
What solution are they providing and what are your business needs?
Are you paying for an eIDV tool and still need to complete the other elements in the CDD process?
Are you paying for a SaaS platform and you're still required to have the AML expertise to use it effectively and be compliant?
Are you paying for a document management system that expects you to keep on top of your record keeping obligations and to run additional searches?
Does the solution save you time, streamline your processes and allow you access fit for purpose professional support?
REMEMBER: CONSIDER YOUR FINANCIAL, REPUTATIONAL, AND LEGAL RISK
Test the Providers Expertise
As we see more audit reports coming through, from providers and the supervisors, it is painfully clear that something needs to change across the industry.
Are your compliance documents fit for purpose? If you have not asked for these then onboarding alarm bells should be ringing. Your provider must be completing checks on your behalf, in accordance with your compliance program and risk appetite. A 'cookie cutter' approach to your CDD just won't cut it.
Who develops their policies, procedures and controls and what is their practical AML experience - in a risk based context? Professional competence that you can rely on is important when your compliance officer is personally liable and your business and clients may be at risk of victimisation.
Do you understand your responsibilities and is your provider supporting best practice? For as start, have they discussed your Know Your Customer requirements with you?
Do they guide and support you in being compliant, whilst protecting your relationships with your clients?
DO YOUR OWN DUE DILIGENCE BEFORE THEY DO YOURS
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