Lawyers and Conveyancers are due to complete their audits by 01 July 2020
Accountants and Bookkeepers are due to complete their audits by 01 October 2020 and;
Real Estate agencies are due to complete their audits by 01 Jan 2021
If you are a reporting entity Section 59(2) of the AML/CFT Act requires you to audit your AML Programme and Risk Assessment every 2 years.
There are a number of considerations:
- The audit is a check of your AML Risk Assessment and Programme by an independent and suitably qualified person and as such the individual/organisation who completed your risk assessment and programme cannot be the independent auditor
- A report will be provided by the auditor outlining whether you meet the minimum requirements of the risk assessment and AML programme and whether the programme was effective throughout the audit period
- The audit is an opportunity to have an independent qualified person review your programme and provide guidance on whether changes are required or peace of mind that your programme is effective
At Customer Engagement Services Ltd (CESL) we provide cost effective independent audit services.
Formed in 2017 we have assisted a number of phase 2 entities in the development and execution of their AML/CFT Programmes and are now assisting entities with their audit commitments.
With thousands of entities requiring audits in 2020 and potential capacity issues to complete we recommend booking your audit time now to avoid this issue.
Our audit process is as follows:
- If you utilize our service a Letter of Engagement will be sent and signed confirming the time of the audit and the scope. Keep this document on file to show the regulator if requested
- An initial scoping discussion will take place with the relevant staff member or compliance officer
- Documents will be requested which can be reviewed off-site or onsite, these documents will include a copy of the Risk Assessment, AML Programme and Policy Documentation, Training register and training documentation where applicable
- Audits can be completed either remotely (depending on ease of obtaining information and access to relevant staff) or onsite. The audit will follow 3 stages- 1) Checking existing documentation against the prescribed requirements of the AML/CFT Act 2009, 2) Confirming adequacy of the documentation based on the nature of the entities business operation and 3) Testing effectiveness of the programme throughout the audit period. This takes the form of reviewing client onboarding documentation, transaction monitoring processes where applicable, staff vetting and training and interviews with relevant staff.
Once the audit has been completed a draft report will be provided for review and commentary. The audit findings will be discussed and if issues are found recommendations provided to remediate.
