Financial Crime Advisory

AML/CTF services

Money launderers are devising increasingly creative ways to use legitimate business to launder the proceeds of crime. The fight against money laundering and terrorist financing is at the top of governments’ and regulators’ agendas.

We can help you comply with your obligations throughout the AML/CTF risk management framework, including:

• • Money laundering/terrorist financing (ML/TF) risk assessment, e.g., review/definition of risk assessment, risk-based approach, and risk appetite
• • Initial and on-going customer due diligence, e.g., review/definition of client risk-scoring processes, know your customer (KYC) processes, know your transaction (KYT) processes, name screening solutions, remediation, and background searches
• • Adequate internal organization, e.g., review/definition of policies, procedures and controls; AML/CTF governance arrangements; management reporting; and training
• • AML/CTF framework compliance review
• • Remediation projects (such as an update of KYC remediation)
• • AML training

Unclaimed assets

Companies, investment funds and financial institutions can be stuck with unclaimed assets due to losing contact with the beneficiary. While from a beneficiary’s perspective it is an asset, from your perspective it is a liability, and can include invoice payables, dividend distributions, bank accounts or insurance policies.

Deloitte can help identify potential points of contact and/or coordinate contact attempts with the beneficiary. If you would like to make a liability consignment request to the Deposit and Consignment Fund (“Caisse de Consignation”), following unsuccessful efforts to contact or locate the beneficiary, we can assist with the required “AML risk assessment” and issue a report as part of the consignment request.

We can assist in any step of this process, for example:

• • Perform open-source intelligence searches to identify potential points of contact with the beneficiary.
• • Perform an AML risk assessment and issue a report according to the requirements of the Caisse de Consignation.
• • Compile the required documentation for the transfer of unclaimed assets to the Caisse de Consignation.
• • Coordinate the entire process.

Download our Handling inactive client relationships flyer below:

Sanctions: European Union/United Nations/Office of Foreign Assets Control/others

Organizations must be able to quickly adapt to the constant changes and regulatory updates of the sanctions framework to avoid facing serious legal risks from breaches.

Sanctions breaches have traditionally carried high and significant regulatory penalties (e.g., exclusion from United States markets) with a high level of accountability of senior management.

Deloitte can help you design, review, enhance, implement and monitor your sanction compliance program through the following services:

• • Sanction risk assessment
• • Regulatory advice
• • Drafting/enhancing your sanction procedures and policy
• • Sanctions training
• • Selection, implementation and/or review of sanction technology solutions (e.g., sanctions name screening, SWIFT, etc.)
• • Retrospective review of processed transactions for evidence of sanction breaches

Fraud prevention

Deloitte’s investigations practice can help you assess allegations of corporate fraud or financial mismanagement and respond to government regulatory requests around alleged financial crime practices.

Your board of directors and senior management have a corporate responsibility to take steps to deter, detect and prevent fraud.

Deloitte’s integrated approach to fraud control can help you understand your susceptibility to fraud risk, identify high-risk areas in the organization, develop a fraud control plan to address these areas of risk, monitor the ongoing effectiveness of fraud risk mitigation, and respond to actual instances of fraud.

We provide:

• • Fraud risk assessment (commercial and financial industries)
• • Fraud prevention
• • Fraud investigation

Deloitte’s whistleblowing services

Deloitte’s global whistleblowing team have been serving clients for more than fourteen years. We have developed a wide range of compliance and digital whistleblowing offerings so that we can help our clients comply with the EU Whistleblowing Directive and establish an effective and secure reporting framework as a key component of their risk management strategy.