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Key AML/CFT Supervisory Initiatives
Risk Assessment Visits including on-site assessments
During the year, a number
of firms were selected for an AML/CFT Risk Assessment Visit
to validate compliance with
the relevant provisions of the AML/CFT Rules. This resulted in
a number of firms entering into
a Risk Mitigation Programme
with the Regulatory Authority
to remediate deficiencies. No instances of money laundering or terrorist financing were detected within firms.
Thematic review projects
Three thematic projects were undertaken in 2015:
Annual MLRO reporting - thematic review
This thematic review was designed to assist the Regulatory Authority to assess the level of compliance by all firms (financial institutions and DNFBPs) with
the mandatory compliance reporting obligations of the MLRO to senior management, and to determine whether firms were adequately managing their AML/CFT obligations and money laundering and terrorist financing risks appropriately.
All financial institutions and DNFBPS were subject to this review, with a number of firms selected for on-site assessments. Overall, the quality of the reports differed from average to good, noting that firms needed to clearly articulate how they assessed the adequacy and effectiveness of their policies, procedures, systems and controls to mitigate money laundering and terrorist financing.
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