Anti-money laundering

Obligated parties within the meaning of the Anti-Money Laundering Act (AMLA) must comply with a large number of regulatory requirements relating to the prevention of money laundering and terrorist financing. The implementation of these requirements, which are constantly evolving, requires appropriate and effective preventive measures as well as proper monitoring, implementation and compliance with these measures.

Numerous regulatory changes

With the publication of the EU Commission's package of measures on 20 July 2021 to harmonise and strengthen measures to combat money laundering and terrorist financing, the banking, financial services and insurance sectors will continue to be subject to numerous regulatory changes (e.g. establishment of the new European direct supervisory authority AMLA, creation of a uniform AML Regulation and new Money Transfers Regulation with provisions on crypto transfers, among other things). It is best to adapt and implement these changes in-house, either preventively or promptly after their establishment and publication.

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Our range of services

With our customised solutions, you benefit from our many years of consulting and auditing experience and our extensive benchmark expertise in these areas in the German banking and financial services market.

We contribute our findings from BaFin monitoring, special audits and participation in the money laundering working group with the supervisory authority/IDW and are happy to support you in implementing the legal and regulatory requirements and innovations with the following services, among others:

Further development of your (group) risk analysis
Risk analysis is an essential component of risk management and serves to provide an overview and analysis of the money laundering risk and to derive appropriate measures to reduce or counteract the money laundering risk using suitable measures. We are happy to support you with, among other things
- Workshops and GAP analyses regarding the implementation of regulatory requirements
- Processing the findings of internal and external audits
- Determining the scope of consolidation relevant to money laundering
- Preparation of a new (group) risk analysis including an appropriate, institution-specific methodology in accordance with the requirements of BaFin AuA AT and EBA guidelines
- Integration of new products and business areas (including crypto)
Monitoring & Data Analytics
With the use of D&A technologies and advanced algorithms, we enable you to extract additional insights from all your money laundering-relevant customer master data and transaction data and thus utilise the inherent risk profile to further develop and increase the quality and efficiency of AML processes and the data completeness requirements of the supervisory authority. High-performance monitoring is crucial for the quality of the hits generated and thus for fulfilling your suspicious activity reporting obligations. We are happy to support you with:
- Analysing the entire population of your customer data and generating analysis findings on AML-relevant data plausibility and risk parameters (e.g. country, PEP, risk class)
- Pattern recognition analysis to obtain objectifiable transparency about the actual and quantitatively characterisable transaction behaviour of the respective customer groups using common attributes (e.g. professional group, industry) or homogeneous customer behaviour
- Determination of the sensitivity of your scenarios/indicators and threshold values used to increase the existing accuracy of fit of your TM system and to demonstrably derive institution-specific scenarios/indicators and threshold values

The entire spectrum of your prevention measures is our terrain for GAP analyses and associated further development at your side:

Analyses of your money laundering-related preventive measures to identify deficiencies and subsequent support for remediation
Support in the design, optimisation and quality assurance of your internal processes and procedures using best practice experience
Support in processing the findings of the annual auditor, internal audit or the supervisory authority with regard to the prevention of money laundering and terrorist financing
Independent quality control in accordance with BaFin AuA BT for your data processing systems
Preparation of a quality assurance concept in accordance with BaFin AuA BT for your data processing systems
Advice on the development of a group-wide prevention and monitoring process
Preparation of a monitoring plan and monitoring concept as well as support in the implementation of monitoring activities by the money laundering officer
Supporting the internal audit department in its audit activities
Support in the preparation of key supervisory audits
Organising training courses and workshops on current topics and for training your stakeholders (supervisory boards, management boards/management, money laundering officers, etc.)

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