Aleph Consulting

Drafting and Reviewing Policies & Procedures

We set up your Compliance Program to include:

• The drafting of Policies and Procedures, in compliance with FIAMLA.
• Risk Based Customer Due Diligence Appointment of MLRO/Compliance Officer
• Ongoing Monitoring
• Training requirements

AML/CFT Business Risk Assessment

A key component of any AML/CFT Program.

Reporting Persons are required to identify, assess and take effective action to mitigate their money laundering risks.

We help you measure their vulnerability and likelihood that their business could be used for Money Laundering or Terrorist Financing.

AML/CFT Client Risk Assessment

Customer risk assessment includes collecting and verifying certain information in order to assign a risk score to a user based on the level of risk.

The assessment's goal is to establish whether a customer poses a money laundering threat, is involved in financing terrorism, is a PEP (Politically Exposed Person) or appears on any relevant sanction lists.

Internal Auditing

Evaluation a company's internal controls, including its corporate governance and its compliance with relevant legislation.

Our internal auditing is an ongoing process to help you stay complaint with legislation on a continuous basis.

We focus on your business internal operations and processes, and provide you with solutions.

Independent AML/CFT Auditing

Section 17 of FIAMLA states that it is an obligation for Reporting Persons to assess and understand their ML/TF risks. The independent AML/CFT audit covers a review of the Risk Assessment and AML/CFT Programme to ascertain that it meets the requirements of the FIAMLA, FIAMLR and relevant rules & regulations. There is a statutory obligation on every Reporting Person to have in place an audit function which will allow the reporting entity to evaluate its AML/CFT programme;

Assistance for onsite and offsite Regulatory Inspections

As part of the AML inspection, the authorities focus on reviewing the following:

• The entity's assessment of exposure to ML/FT risks;
• The completeness and effectiveness of AML policies, procedures, controls, and systems, including Customer Due Diligence measures;
• The level of AML awareness within the team
• The support provided by senior management to the AML framework.