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Are you learning from your mistakes?

Are you learning from your mistakes?

“This finding was also made in your last audit” is a comment that appears all too frequently in audit reports for both Phase 1 and 2 reporting entities. It is also a potential red flag for AML supervisors, who indicated several times last year that they will be ramping up enforcement activities for non-compliance.

What this indicates to an AML supervisor is that the reporting entity is not taking their AML/CFT obligations seriously, nor reviewing audit findings and implementing remedial steps to put things right. Failure to put things right is not only a failure to meet obligations under the AML/CFT Act 2009, but also the Companies Act 1993.

Now is the time to review your last audit report and make sure that all the recommendations have been addressed. This is an opportunity to learn from past mistakes and set yourself up for hassle free audits in the future.

If you are not sure how to implement any previous recommendations into your AML policies, procedures or controls please don’t hesitate to contact the friendly AML compliance team here at Strategi.

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