Boltons Legal Chambers - Kampala, Uganda

The key driver of any AML Compliance Program is the Risk Assessment Report. A Risk Assessment is not required by Law or any Regulation, it is, however, a regulatory expectation and some argue a best practice in order to establish a Risk-based Compliance Program. From an AML Risk Management perspective, it's recommended to take an exhaustive inventory of your Products and Services, Customer and geographies where you conduct business; this informs the scope of the AML Compliance Program and the content of the Policies, Procedures and Internal Control framework. The AML Risk Assessment is the roadmap to develop the internal controls needed to protect the organization from Money Laundering and Terrorist Financing risk. The AML Risk Assessment informs your training program and drives the periodic testing of Internal Controls.

The AML Auditor is your partner in delivering the audit process, they are not your adversary. Gone are the days when another person within the organization performed the Independent Review as there is too much at stake when it comes to AML Compliance. When engaging an AML Auditor don't buy on price - buy on expertise and value. Your AML Auditor must have the knowledge, experience, and skills to properly Plan, Scope, Review and Test all the relevant elements necessary for the AML Compliance Program to state whether it conforms to requirements and is adequate. It's important that they have the Credentials, Experience, current AML knowledge, and provides a proper proposal including the Scope of Work, Deliverables, Timings, and Terms. We recommend that your AML Compliance Audit be included in your annual budget.

The adequacy of AML Training ensures that all appropriate staff understands their responsibility for compliance? An Auditors interview with key AML personnel will reveal whether they have been properly trained if they understand the compliance program requirements and if they understand their responsibilities. The AML Regulations demand that staff are trained in the regulations as well as the organization's Policies, Procedures, and Processes. Caution: It's not about adding a couple of slides to the Compliance meeting and calling it AML Training. Your staff is the first line of defense in spotting suspicious transactions. It's recommended to conduct at least 3 AML Training Programs per year.