Compliance Framework Development

Williams McGuire draws on its experience, precedents, and document library to design, develop and refine Reporting Entity compliance frameworks.  Upper-range compliance frameworks typically consist of:

1. AML and Economic Sanctions Compliance Policies:  A set of rules that clearly and simply articulate organizational commitment to risk-based compliance and money laundering and terrorist financing detection and deterrence.
2. A Compliance Framework:  That sets out the CAMLO’s blueprint for continuously meeting AML and Economic Sanctions compliance policy objectives, including job descriptions for individuals with significant AML responsibilities.
3. An Inherent Risk Assessment:  That clearly describes the inherent money laundering and terrorist financing risk facing the business because of their product and service mix, client characteristics, and geographies relevant to their operations, considering: legislative requirements and regulator guidelines; research and statistics from authoritative sources; organizational experience; contemporary money laundering and terrorist financing trends and typologies; and empirical analysis.
4. A Risk Mitigation Document:  That explains the business’ approach and specific control measures to mitigate activities identified as high risk in the Inherent Risk Assessment, including triggers and measures for de-marketing clients.
5. A Technology Framework:  That details the use, tuning, and oversight of technology employed to monitor AML and Economic Sanctions risk and compliance.
6. Roll-Specific and Modular Procedures:   That explicitly tie to policies and simply explain the task, timing and ownership of each requirement.
7. Training: That is auditable, documented and role specific, for those within an organization with or without AML responsibilities (including employees, agents, management and directors), which considers operational realities, as well as AML and Economic Sanctions policies, procedures and risks, operational realities.