From 1 July 2018, most lawyers are captured under the AML/CFT Act and therefore have several AML/CFT requirements. These requirements include:
- Appointing a compliance officer;
- Conducting a Risk Assessment;
- Developing an AML/CFT Programme based on the Risk Assessment;
- Keeping AML/CFT documents up-to-date;
- Conducting Customer Due Diligence;
- Regular staff training on AML/CFT;
- Annual reporting on AML/CFT to the DIA; and
- AML/CFT Audit every two years, which involves having the Risk Assessment and Programme audited by an independent auditor(the first audit must be conducted before 1 July 2020)
We highlight the obligation to arrange an AML/CFT Audit, before 1 July. Although the AML/CFT Supervisors have given some relief with verification, they have not yet announced timing changes to the audit requirement.
Now is an opportune time to arrange an independent AML/CFT audit, even if it needs to be delayed.
Contact us to discuss an audit.