The use of independent, third-party companies to conduct this Due Diligence effort is considered a best practice, rather than using an outside auditing firm that sometimes can be “too close” to a situation to accurately assess risk. We are objective and independent and will tell our clients what they need to know, not necessarily what they want to hear. As the world has become a more global marketplace, the risk factors related to money laundering have increased.
In our risk assessments, we review how controls and policies are implemented and identify actual and potential gaps. During the Audit and Review process, we review and assess AML compliance with company policies and procedures, test the current audit program, review currency aggregation procedures, review existing internal policies and procedures—including high-risk countries, OFAC, and Politically Exposed Persons—review internal audits, review how critical information is gathered and stored in order to identify suspicious transactions and make recommendations how to enhance these procedures or validate that current procedures are sufficient.