Review of AML and CFT systems and controls

Our client, a UK branch of a Taiwanese bank, approached us in late 2016 to undertake a review of their AML and CFT systems and controls to ensure they are fit for purpose and that the first line activities carried out are effective and compliant with UK legal and regulatory requirements.

Our client required a report detailing the findings of our review which they could provide to their internal stakeholders.

Project Objectives

  • Review the firm’s AML / CFT governance arrangements, including MI and compliance monitoring
  • Review the AML / CFT policy and procedures, including the process for reporting suspicious activity to assess compliance with UK legal and regulatory requirements
  • Review the firm’s business and customer risk assessment methodology and outputs
  • Assess the application of customer due diligence requirements through sample testing
  • Test the effectiveness of screening and monitoring processes
  • Outline findings and recommendations in a report

How Bovill Helped

  • We assessed the effectiveness of the firm’s AML and CFT systems and controls
  • We helped the business understand the FCA’s expectations in relation to AML and CFT systems and controls
  • We provided advice to senior management, the Money Laundering Reporting Officer (MLRO) and the compliance team
  • We made recommendations for areas that require improvement, this included practical changes to the firm’s screening and transaction monitoring processes


The client is aware of the areas which require improvement. The report identified the areas which should be treated as higher priority to enable the client to focus resources appropriately.

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