Anti-Money Laundering, Counter Terrorist Financing and Sanctions

Addressing the threat of money laundering and financing of terrorism requires a comprehensive approach taking into account your people, processes, technology, governance and assurance. Combining this into a framework forms the basis for a robust risk management system. Increasing vigilance is necessary to ensure that risk-based controls are adequate, effective and proportional to your organisational risk. Managing ML/TF risk should be an on-going, strategic business imperative.

Issues you may be facing

Risk Management

  • Assessing your organisation’s money laundering and terrorist financing vulnerability
  • Considerations for implementing a risk-based approach to managing ML/TF risk
  • Establishing and implementing an effective AML/CFT risk framework
  • Knowing how to identify, assess, manage and mitigate AML/CFT risks

Governance and oversight

  • Identifying the requirements for global, regional and jurisdictional policies
  • Preparing for AML/CFT assurance or regulatory reviews
  • Assistance with remediation and other action to address AML/CFT gaps identified during assurance and regulatory reviews
  • Setting up appropriate governance and organisational structures to evaluate and address AML/CFT risks as they arise


  • Defining the levels of AML/CFT training for the various stakeholders in your organisation
  • Assessing roles and responsibilities of key AML/CFT/Sanctions staff
  • Defining appropriate job descriptions and associated key performance indicators

Process and Technology

  • Understanding the impact of the varying customer due diligence and KYC requirements on your customers
  • Identifying and dealing with higher risk relationships e.g. correspondent banks, politically exposed persons, trusts and partnerships
  • Dealing with transparency and beneficial ownership requirements for legal persons and legal arrangements
  • Establishing effective records management practices
  • Meeting your regulatory obligations with regards to record keeping  and document management while reducing the impact on your customers
  • Meeting the various AML/CFT reporting requirements e.g. suspicious transaction reports, cash threshold reports, etc.
  • Identifying the technology and process requirements for AML/CFT/Sanctions risk management


How we can help you


  • Organisation-wide ML/TF risk assessments
  • Specific risk assessments of e.g. customers, products, delivery channels and geographies
  • The evaluation of your business and identifying, assessing and taking effective action to mitigate ML/TF risks taking international standards and local regulatory requirements into account
  • Establishing and implementing AML/CFT risk frameworks within which to manage your organisation’s risk
  • Identifying key AML/CFT risk elements and factors to include in your organisational AML/CFT risk framework
  • The design and development of AML/CFT risk frameworks which integrate with your wider Enterprise Risk Management Frameworks and meet with the COSO standards
  • Risk rating models for your various business relationships with the relevant supporting due diligence processes
  • The design and development of AML/CFT policies and supporting policies, taking into account your global, regional and jurisdiction operational and regulatory requirements
  • Implementing processes for the ongoing review and governance of your policies
  • The design and development of tailored governance structures, roles and responsibilities, reporting frameworks and processes
  • Assistance and guidance in preparing for, documenting and managing assurance and regulatory reviews.
  • Providing your organisation with the necessary AML/CFT skilled resources to drive remediation programs in preparation for initial or follow-up reviews
  • The development and implementation of appropriate AML/CFT training for all levels of your organisation, from top executives to front line staff
  • The appointment of a person to manage AML/CFT risk



  • Implementing enhanced and simplified due diligence measures
  • The design, development and implementation of various due diligence processes within your organisation to meet regulatory requirements, while remaining customer centric
  • The development and implementation of due diligence processes dealing with ultimate beneficial ownership
  • Establishing effective records management practices with supporting systems and processes
  • The development and review of customer due diligence, transaction monitoring, and suspicious transaction processes and systems to ensure adequate operation
  • Evaluation of the effectiveness of list management and matching rules in sanction systems
  • Identifying and sourcing the most appropriate technology solutions and systems implementation partners for your AML/CFT programmes

Contact us

Roy Melnick
Associate Director
Tel: +27 (0)11 797 4064

Contact us

Mark O'Flaherty
Tel: +27 (0)11 797 5885

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