AML Effectiveness Reviews

Mature AML programs can still harbor hidden compliance gaps. Platino Consulting’s independent AML effectiveness review for a money service business (MSB) pre‑empted its FINTRAC examination by uncovering incomplete know your customer (KYC) documentation, missing policies and procedures .

Deep‑Dive Audit
Benchmarking against FINTRAC’s Compliance Program Requirements and Assessment Manual, Platino Consulting found 25% of corporate‐client files missing beneficial‑ownership data—contravening PCMLTFR mandates. We also detected failures to aggregate same‑day large cash and virtual‑currency transactions, risking under‑reporting.

Remediation Roadmap
Platino Consulting prioritized fixes—rewriting KYC/EDD policies, automating EDD checklists for PEPs, and deploying system updates for aggregation rules—all aligned with FINTRAC’s Risk Assessment Guidance.

Fractional‑Officer Transition
Embedding a senior Advisor as a fractional AML Officer, Platino Consulting instituted quarterly “health‑checks” and continuous calibration under FATF’s risk‑based approach.

Outcomes

• Rapid Gap Closure: 80% of blind‑spot issues resolved in three months during Platino Consulting’s remediation project with the client.

• Inspection Success: No significant findings in the MSB’s FINTRAC exam.

• Sustainable Assurance: Ongoing controls now institutionalized.

Concerned about hidden compliance gaps? Contact us to book a no‑obligation consultation - where we can discuss your needs for an AML effectiveness review.