AML/CFT Compliance Guidance Services in Ghana

Review of AML framework – Gap Assessment

Gap analysis involves a comparison of existing policies and procedures in place with the organizations with the required policies and procedures. It helps the organizations to identify “where we are” and “ where we want to be”. The broad areas which will be covered during the gap assessment of the AML framework include the following:

• Review of Corporate governance Policy and structure of AML.
• Review and development of AML Policy and procedure including the review of Know Your Customer, due diligence, and Enhanced due diligence process.
• Review and development of Risk Management framework.
• Review of IT systems – core solution and AML solution covering risk profiling, screening, and monitoring of customer activities and transactions.
• Statutory Reporting and MIS.
• Training – Staff and Board members.
• Identify the gaps or differences.
• Document management system.

AML/CFT Policy and Procedures

AML/CFT Policy and Procedures define the guiding policies for adequate prevention and control. It includes procedures for the detection and reporting of activities possibly linked to money laundering or the financing of terrorist activities. It is the policy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorists or criminal activity.

We cover the following areas in line with regulatory requirements:

AML/CFT – AUP Audit and IT System Review

• Check for mandatory fields as required by the regulator.
• Check for Onboarding and Transaction Process flow of clients.
• Check AML solution – Risk Profiling, Screening, and Monitoring Process Flow.

Assessment on the effectiveness of AML Risk Solution built into the IT system and to identify gaps if any to ensure the system covers the following aspects.

1. Verify if the AML Risk Solution follows the standards of the regulatory Authority of Ghana.
2. Verify if the screening solution is having options to integrate in real-time with world check / Dow Jones / etc.
3. Verify if Central Bank of Ghana lists and other watch lists can be added to the tool for screening purposes.
4. Verify whether the system is having the capability of reducing the false positives.
5. Ascertain and verify the logic developed for matching the names against the sanction list and to check the percentage of the match based on different parameters.
6. To provide additional inputs for customer risk profiling solutions to ensure those are in line with the NRA document shared by the Regulator.
7. Verify the logic of the risk profiling of customers is covering various parameters.
8. Verify if various scenarios required for the regulatory authority are available in the system and the tool can monitor either on a real-time or post-transaction basis.
9. Verify the escalation process available in the system.
10. Ascertain if the modules on suspicious transaction reporting are integrated into the system and risk scoring assigned accordingly.
11. Verify whether the system has the features to create/develop scenarios/rules based on business requirements and future regulatory needs.
12. Verify the availability of reports and audit logs.
13. Ascertain whether the master screens have proper dual control in place for risk mitigation.

• Check case Management/escalation Process.
• Check Documentation Storage Process.

Customer KYC and Due Diligence – Compliance requirements

1. Verify the process of enhanced due diligence for High-Risk Clients.
2. Verification of Site visits to be conducted as per the nature of the licensee’s business.
3. Verify the process for KYC and Screening methods.