Desk-based reviews are usually the first step of any supervisory targeted compliance programme and are purely a paper-based exercise. This approach aims at inspecting audit reports produced by your AML/CFT auditor and examining whether you have appropriately addressed any areas of non-compliance identified. These reviews are helpful for the supervisors because they can use them as a quick indicator to see if there are any red flags.

Onsite reviews are more in-depth and involve testing of processes to make sure that you are actually doing what you say you are doing. This could involve checking bank transactions or client information for example. If you have a successful desk-based review then it is less likely that the regulator will want to visit you, but obviously not a guarantee (and random visits are not unheard of). 

Given that reporting entities have completed at least one independent audit, it is likely the supervisors will utilise this tool in their review methodology more than ever. Therefore, more than ever before, it is important that you appoint a competent and experienced AML/CFT auditor who not only helps you identify the deficiencies within your AML/CFT system, but also adds value to your business by providing recommendations on how to improve.

Desk-based reviews should be welcomed and at the very least considered a learning opportunity. If you are nervous about a review, then get in touch with our team. We can help you to get on the right path and make sure your review is a good experience.