AML & Sanctions Risk Assessment
March 16, 2022
AML Risk Assessment enhancement and standalone Sanctions Risk Assessment development for a multinational Asian Bank.
FTI was engaged by a multinational Asian bank (the ‘Client’) to enhance its existing AML Risk Assessment and develop a standalone Sanctions Risk Assessment for all its branches and subsidiaries based in at least 16 different countries.
The impetus for the Client to develop a standalone Sanctions Risk Assessment was partly owing to OFAC’s issued guidance on the sanctions compliance programmes, as it emphasized that the risk assessment be an integral part of the Sanctions programme, policies, procedures, and training.
Our role included:
- Review of existing AML Risk Assessment and provide enhancement recommendations
- Design and implementation of AML and Sanctions Risk Assessment
- Providing training to staff in conducting Risk Assessments to enable staff to conduct assessment independently moving forward
Assisted the Bank to:
- Identify deficiencies and inform opportunities for improvement in AML and Sanction processes
- Make informed decisions about risk appetite and the implementation of control efforts, allocation of resources and technology spend
- Understand how the structure of a Business Line’s AML & Sanction compliance programme aligns with its risk profile
- Develop risk mitigation strategies including applicable internal controls and therefore lower a Business Line’s residual risk exposure
- Ensure senior management are made aware of the key risks, control gaps and remediation effort
- Ensure that key risks highlighted by the regulator are catered in their assessments