Having implemented an AML/CTF program you’ve identified how reliant you are on other businesses or teams performing core pieces of it. In many cases some of it is outsourced to 3rd party providers or you are reliant on the accuracy of their algorithms and lists. We have all heard stories, urban myth thought they may be, about business units or teams just not performing key functions or giving key functions no priority. Are declarations of compliance suitable without being supported by evidence?
Whether you are a board member, in the business or in compliance the ability to identify issues quickly and stop them becoming systemic is what stands between you and the business or you being fined.
How do you monitor compliance with your program? How can you provide assurance to the board and business units that the entity is actually complying with its own program?
In developing your assurance program you need to understand how various functions are performed, how effective, how accurate and timely your controls really are.
This program will work through the intricacies of developing and managing an ongoing assurance program. We all understand that there are many moving parts in any program so what are the areas you should focus on and where do your weaknesses lie?
Using real examples as case studies and identifying the benefits and pitfalls, this program is designed to help you understand:
- What a compliance program is trying to achieve
- Tolerance thresholds - what is a one off and what is systemic?
- Identifying the areas of risk, potential failure points and over reliance on others
- The importance of taking a holistic view
- Looking at control effectiveness
- Risk allocation and accountability
- Building a compliance assurance program - big bang or block by block
- Managing and monitoring 3rd parties and out-sourced partners; and
- Reporting formats and dashboards..
Learning Objectives:
- Developing a compliance assurance program
- Targeting high risk and unsupervised areas
- Dealing with outsource partners who may be performing key functions on your behalf
- Using Data and deep dives
- Undertaking reviews.
Areas Covered:
- Control Frameworks
- Program Governance
- Encouraging compliance and undertaking assurance programs
- Examples of issues (case studies throughout the course)
- Assessing transaction monitoring rule effectiveness and making a case for change
- Assessing and monitoring contract performance and goods supplied post the contract award
- Monitoring and testing for compliance
Who will Benefit:
- Board Members
- CRO's
- MLRO's
- AML/CTF Teams
- Financial Crime Compliance Managers
- Internal Auditors
- Regulatory
- Compliance
- Internal and Independent Auditors
- Staff with Roles and Responsibilities in AML Management and Oversight
- Risk and Compliance Management
- Compliance Analysts and Advisors
- Company Management
- Operational Risk Managers
- Registration Process: 8:30 AM – 9:00 AM
- Lecture 1: Making the case for an AML/CTF assurance program
- What do we mean by an assurance program?
- The difference between audit assurance and program assurance
- Identifying how much you rely on others to perform key functions
- Communicating the issues to the board and getting buy in
- Lecture 2: What makes an effective AML/CTF assurance program?
- Identifying the key controls and the assumptions that sit under them
- How regular should your reporting be?
- What data is important for your assurance program?
- The difference between a deep dive and indicative data
- Lecture 3: Key considerations
- Reporting for reporting’s sake
- When is an issue systemic?
- Do you go big bang or build a program piece by piece?
- Lecture 4: Approval and oversight by the board and senior management
- Lecture 5: Building an AML/CTF assurance program
- Clarity around the objective
- Who will undertake it and what level of independence is there?
- The ability to rely on other reporting that may be available
- Stability and consistency
- Managing ongoing compliance
- Who is doing what and when?
- Multi-national programs
- Business versus Group compliance monitoring
- Operational compliance and / or regulatory compliance
- Identifying the KRI’s that provide meaning
- Inclusion of deeper dives
- Lecture 6: Building an AML/CTF assurance program
- Frequency
- Target State
- Driving value and pragmatism
- Excluding parts of the entity from oversight
- Responding to identified issues
- Q and A
David Harley, CFE CAMS
Director at Delta Financial Crime Consulting Pty Ltd
EXPERT David Harley CFE CAMS – is a skilled and effective Anti-Fraud, Anti-Corruption and Anti-Money Laundering professional with over 30 years’ experience preventing, detecting and resolving issues that relate to fraud, corruption money laundering and terrorist financing. With a law enforcement background focused on criminal investigation and proceeds of crime, David has spent nearly 18 years working in a commercial environment dealing with fraud and corruption.
David has led the development of frameworks and policies, undertaken business partner reviews and lead a range of fraud and corruption investigations, across multiple jurisdictions, including Australia, Bangladesh, China, Indonesia, Papua New Guinea and the Pacific Islands.
He possesses an extensive repertoire of strategic and tactical knowledge and skills, including forensic technology, forensic accounting, data analysis and a range of investigation skills/methodologies, and is able to provide commercially and ethically sound remediation recommendations and systems-based solutions to mitigate future risks. David takes a holistic approach to risk and issue management and is committed to leaving a lasting and beneficial impact on businesses that extends long after the engagement is completed. An excellent communicator, teacher and mentor who regularly lectures in Certificate III in Investigative Services and Certificate IV in Government (Investigation) for registered training organisations.
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