AMLGS: Ontario AML/ATF Healthcheck – Why Does My Company Need It?
“Is your AML/ATF program compliant?” – This is the question that Ontario-based operators are being asked as part of the IGO’s evaluation on effectiveness.
To summarise; all operators will be assessed by the IGO on a quarterly basis (or more frequently if it is deemed necessary). The aim, to determine if the AML program in place is fit for purpose and compliant with the regulations and guidance provided.
For this AML review, operators are given a two-week notice that the assessment is going to begin…not much time when you compare this to many other regulated markets where you are frequently given 4-8 weeks (or longer in some cases where the regulator has been known to postpone assessments at short notice).
In addition, Operators must have an independent party conduct a review of their AML Program annually and provide IGO with a copy of the review/audit report that outlines scope, observations and remediation steps/timelines.
These reviews will be very in depth and cover the foundation of any AML effectiveness evaluation. For example, as part of the review the IGO will;
- Collect the appropriate documentation from the respective Operator including AML/ATF policies and
- Conduct sample-based testing to ensure conformity with regulatory requirements and/or adherence
- with AML/ATF policies and procedures
- Interview certain employees at the Operator that are related to AML specific activities
- Participate in system demonstrations with the Operator
Operators need to be ready for these reviews and the best way to do this is to conduct your own AML Health Check. Many UK and MGA-based operators have in place an AML Healthcheck with AMLGS where we follow a similar format to the regulators but with the added support of working with you to make the developments needed to maintain compliance, and demonstrate this to the regulator.
Time and time again we see experienced operators fail assessments due to the fact they are not adequately conducting sufficient self-assessment; A self-assessment which is a small price to pay in comparison to regulatory enforcement and everything that comes with it.
AMLGS has evolved it’s AML Health Check specifically for our Ontario operators, some of which have already been utilised and benefited from. We are urging all operators to do the same so we can continue to have a compliant and thriving market in Ontario and ensure that regulatory guidance is respected.
Take a look at what the AML Health Check entails – http://amlgs.com/services.html
We look forward to you reaching out to our team to discuss how we can support you in your review so that you can have the assurances prior to your next regulatory AML assessment.