Legislation on money laundering is complex and is renowned for its strict rules and regulations, with recent sanctions reaching record levels.
Companies and individuals can be caught up in money laundering unknowingly as offences can be committed not only where a person has knowledge of money laundering, but also where they merely suspect it. We can help you find solutions to both the known-knowns and the unknowns-unknowns.
Our AML services usually start with identifying the applicable regulatory AML framework starting at the level of European regulation down to the local level of relevant rules and practices with the support of local AML experts (Fieldfisher experts or other trusted colleagues within our international network).
This allows us to design a tailor made AML program starting at the group level and supplemented by a local section for the relevant jurisdiction. Such program includes the drafting of AML policies and procedures as well as manuals and checklists. With respect to the implementation of the AML policies and packages an efficient data collection requires the drafting of a standardized questionnaire, a data collection sheet and a document request list. The information request needs to be in line with the regulatory framework and should allow the client to make a proper risk assessment (KYC and CRA).
In case a client wants Fieldfisher to perform AML-KYC analysis as an outsourced service, we are ready to provide such services. We are also prepared to offer external compliance functions as our team includes certified AML officers. Additional services can be rendered on a case by case basis subject to the needs of the business.
Range of Services
Our team offers unrivalled advice to clients on all the key pieces of European AML legislation which govern money laundering. Our high level of experience means we provide truly expert advice to companies and individuals who are subject to investigations concerning money laundering. We go beyond traditional legal advice, by helping companies with implementing anti-money laundering procedures for compliance with European and national AML laws and regulations and to minimise the risk of being investigated for offences.
We therefore offer a variety of AML services within a modular system with individual building blocks that vary subject to the needs of the client:
- AML governance review in particular jurisdiction
- AML risk management review
- Assistance in the design of AML program or review/assessment of existing program
- Assisting in the drafting of AML policies and procedures to be in line with the local regulations
- Quick support with data collection and completion of reports, including UBO identification, performed at a relatively low cost by legal support staff of our international Condor Flight Service line by using third-party databases such as Name Scan and Lexis Diligence
- Business Risk Assessment Consulting (BRA)
- Know Your Customer (KYC) Consulting and Customer Risk Assessment Consulting (CRA)
- Subject matter expert review of higher risk KYC files
- Regular KYC file refresh
- Transaction Reviews/Lookbacks/Investigations
- Providing regular AML compliance reviews and remedial services and providing recommendations for improvement
- Designing and delivering of tailored and focused AML training programs aimed at various levels of the staff complement within your organisation
- Assistance with responding to regulatory inspections and requests
- Assisting in the preparation of regulatory returns, e.g. Risk Evaluation Questionnaire (REQ)
- Providing other AML Consultancy Services
- Defence in administrative offence proceedings
- 24/7 AML Hotline