While each sector has its own unique areas of concern for the supervisors, overall, there are many similarities across the sectors. When reviewing your AML/CFT policies, processes and controls prior to your audit, it may pay to focus some of your attention on the general areas the supervisors have highlighted, for example: 

1. Have you reviewed the recommendations outlined in your last audit report? The supervisors are expecting that you will have an action plan in place to remediate any deficiencies highlighted.
2. You have taken the time to draft policies, procedures and controls but are you actually following what you have written. If you have procedures that are too complex for your business, take the time to review and amend if appropriate.
3. Make sure your staff know what your sector specific red flags are and what to do if they come across one. We find that many reporting entities focus their training on processes e.g., identity, address verification and enhanced due diligence, which is great, but often staff remain unaware of what a red flag is and how to deal with it.
4. It is important that your programme sets out your policies, procedures and controls for training for all employees with AML/CFT duties (Compliance Officer, Senior Managers etc). The next step is to make sure the training is completed and recorded as outlined. 

 Reviewing these key areas and making sure you are compliant is a good starting point to stay out of the supervisors’ sights. Get in touch with our team if you have any questions on this important topic.