Independent AML Review: The bronID Process

So you are thinking of hiring bronID for your next Independent Review of your AML/CTF Program. Before you get started you want to know what the bronID process looks like. In this article we will outline the step by step process bronID employs to perform an Independent review.  

Defining the scope

Before deciding on bronID as your vendor, you can book a free consultation where you can talk to an AML specialist and discuss your needs and the scope of the intended review, together with the reasons for getting the Independent Review such as a regularly scheduled review, a request from the regulator, request from a third party, etc. This will help bronID define the scope and make a risk-based analysis to define the priorities of what needs to be tested and how.

Hire bronID as your Independent Reviewer and sign our Standard Services Agreement

If you decide to go with bronID, we will send you our Standard Services Agreement that outlines the scope of the review, the milestones and deadlines for delivery and the overall interaction between your company and bronID during the review process.

Fill out your business information and upload relevant documentation

At the start of the review, we will send you a link to our online tool where you can provide relevant information about your business and upload the compliance documents that you have, such as your AML/CTF Program, your identity verification procedures, previous audit reports and other relevant compliance manuals. Our tool automatically processes the documents and gives our team a preliminary overview of your company.  

Audit Questionnaire

Book the Initial Review Interview

Once you finish the online questionnaire tool, you will be redirected to a calendar where you can book the opening review interview. You should invite the relevant team members within your company that are involved in setting up and executing the AML/CTF policies, procedures and controls. At the opening meeting we will discuss your procedures and controls in detail, identify the relevant stakeholders within the organisation, and review the tools that you are using that need to be inspected and tested.

Book Audit Meeting

Follow up meetings  

Based on the opening interview, we will schedule follow up meetings with your company to review and test your internal AML/CTF processes. This will include review and testing of your customer due diligence processes and files, your transaction monitoring procedures, review of a sample of transactions, review of employee and team member credentials, etc.  

Final Draft Report

Once we thoroughly review the supplied documentation and test your internal procedures and controls, we will draft a detailed and comprehensive report. We will send you this report so you can comment on it before finalising and certifying it. You can comment on our interpretation of your documentation and review if our understanding of your processes is correct and if we have missed anything.

The report will include the following:  

Executive Summary: Summarises key findings, concerns, and recommendations, providing a snapshot of policy and control effectiveness.

Definitions: Clarifies essential AML/CTF terms to ensure understanding across all report readers.

Scope: Details the extent of the audit, which can range from comprehensive evaluations of all AML/CTF aspects to focused audits on specific areas due to regulatory requests or identified deficiencies.  

Methodology: Describes the criteria and rating system used for assessing technical compliance, execution, and effectiveness, offering insights into the evaluation process.

Findings: Presents detailed observations of compliance gaps, execution issues, and effectiveness areas needing improvement, with all assessments being risk-based and tailored to the entity's profile.  

Recommendations: Provides specific, actionable advice for addressing identified issues, with both immediate and long-term solutions.  

Colour-coded Compliance Ratings Table: Offers a visual summary of compliance, execution, and effectiveness ratings, highlighting priority areas for improvement.

This report is essential for entities to showcase their AML/CTF compliance efforts, providing a comprehensive analysis and guidance for enhancing their regulatory frameworks.

Final Report and Certificate

Once you confirm that all relevant points are included in the report, we will finalise, digitally sign and certify the report. You will get a digitally signed and certified attestation letter as well as a detailed report that you can share with the regulators and relevant third parties.

The entire process may take 2-4 weeks, depending on the complexity of your organisation. If you are interested in conducting an Independent AML/CTF Review, you can book a free consultation with bronID and get the process started.

Written by
Emma Poposka
Certified AML/CTF Specialist

Stay informed about recent events and get regulatory updates to your inbox.