Independent Review

To ensure compliance with your reporting agency and to avoid any administrative penalties, an effective Compliance Program should be implemented. A crucial component of your Compliance Program and a requirement is an Independent Review of your Policies and Procedures to test their effectiveness.

An Independent Review from CAPI Solutions helps with:

  • analysis of operations, structure, locations, services provided, and geographies served.
  • interviews with personnel regarding compliance and the risk of money laundering and terrorist financing, as well as corporate structure and regulatory registration.
  • understanding and reviewing the compliance officer / CAMLO appointment and reporting to the owners on the compliance program and program effectiveness.
  • detailed, in-depth review of  documented policies and procedures to ensure adequate and comprehensive coverage, including customer identification (KYC), regulatory reporting including suspicious and terrorist property reports, ongoing monitoring of relationships, and enhanced due diligence (EDD) procedures on higher risk areas.
  • reviewing documentation of the assessment of money laundering and terrorist financing risks. This includes reviewing risk mitigation program and procedure documentation.
  • understanding of the risk rating methodology used to risk rate customers, especially regarding how higher risk identification is executed.
  • inquiring of, reviewing documentation and testing the ongoing training program; staff interviews.
  • testing of identification and recordkeeping requirements.
  • understanding and testing the process to monitor transactions, detect and handle any potentially suspicious activities.  Including analyzing transaction data, reviewing documentation (STR’s), and alerts to validate that the alert or rule is operating as intended.
  • testing the process for screening the names of the designated persons and sanctioned individuals and entities against OSFI (Canada) OFAC (USA)  and other relevant terrorist lists, including how potential matches and false positives are handled and documented.

The CAPI team’s goal is to have an ongoing relationship with the clients, lasting beyond the audit process.

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