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In response to the growing regulatory scrutiny and continuous struggle to effectively design & implement AML Compliance programmes, PwC has developed a dedicated AML Health Check Assessment.
Our solution aims at supporting obliged entities in identifying potential gaps and areas for improvement, supplemented by critical and priorities assessments. Our recommendations are based on regulations, market's best-practices and our extensive experience.
Our multi-dimensional review scope aims at providing a holistic institutional view that can be tailored to any particular areas of interest
Culture
Culture
Tone from the Top
Compliance Culture
Trainings
Governance
Governance
3 Lines of Defence Model
AML Policies architecture
Role and Responsibilities
Management reporting
Risk Management
Risk Management
Enterprise Risk Assessment
Risk Appetite approach
Customer Risk Rating methodology
Controls environment & management
Monitoring Process
Monitoring Process
Know Your Customer process
Transaction monitoring scenarios
Sanctions Filtering
Negative News Screening
Staffing
Staffing
Compliance staffing adequacy
Compliance staff development
AML Tools
AML Tools
AML IT solution landscape
Automation Potential
AML Health Check Process
Results are presented in a corroborate and simplified way with focal points clearly highlighted
Why PwC?
Our experience and tested approach allows us to conduct AML Health Check with minimal impact on your daily operations
Efficient approach
Efficient approach
Depending on the scope we are able to perform the review in ca. 5 weeks
Flexible scope
Flexible scope
We can concentrate on the areas of interest where you perceive potential weaknesses
Proven methodology
Proven methodology
We have conducted multiple AML Health Checks across Europe
Pragmatic mindset
Pragmatic mindset
Our main goal is to provide you with a down-to-earth view on the potential risks and deficiencies
Embedded best market practices
Embedded best market practices
Our team have worked on over 120 AML projects in more than 30 countries
Solution and business oriented
Solution and business oriented
Proposed mitigation actions combine compliance and commercial institutional goals
Credentials
One of the largest Polish banks
Project
Review of the AML program in light of compliance with the relevant AML / CTF regulations together with recommended actions for one of the Polish Banks
Context
The Bank had requested a review of their internal AML policies including Know Your Customer, Transaction Monitoring and compliance with Polish AML regulations in line with local and global market best practices.
PwC approach
PwC supported the Bank by reviewing the policies and procedures to create suggested solutions aimed at addressing the identified deficiencies and inconsistencies.
One of the Top 5 Polish Bank
Project
Review of the internal AML policies and procedures for one of the Top 5 Polish Banks.
Context
The Bank requested a complex review of their AML policies and procedures across multiple business lines in conjunction with local regulation compliance assessments and market best practice comparison.
PwC approach
Our team conducted a comprehensive review of the internal policies across multiple business lines including retail, corporate and institutional banking. PwC focused on understanding the Bank’s compliance culture, working instructions defining AML policies and its practical implementation. Based on that methodology a detailed report was created that identified inconsistencies and areas for further improvement.
Online Sport Betting Company operating in Poland
Project
Providing an expert review of pre-selected samples regarding the potential of suspicious AML activity.
Context
The company requested support in the analysis of identified samples of potential Suspicious Activity Reports. The samples were KYC profiles and transactional histories of pre-selected AML outliers.
PwC approach
The objective of the expert review was to analyse the pre-selected samples for potential suspicious activity. PwC provided a case summary for each item outlining the identified potential risks and supporting rationale. The analysis was done on a best effort basis taking into account the Polish regulatory framework and market practices, the analysis did not advise on the regulatory reporting matter.
An International Banking Group
Project
Providing a comprehensive assessment of the Compliance Framework
Context
PwC conducted and reported analysis of the Bank's compliance Risk Framework. The aim was to satisfy European Central Bank request and to identify areas where the Compliance framework should be improved in various entities of the Group (in many jurisdictions).
PwC approach
PwC focused on following dimensions of Risk Analysis; Governance, Framework and Organisation; Culture, Integrity and People Strategy; Technology and Data Management. The final report presents an executive summary of the gap and prospect analysis, detailed observations and recommendations for the Group and individual locations (several countries).
Related content
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Sources:
1. United Nations: Office on Drugs and Crime
2. LexisNexis
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