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WHAT IS DURRUS COMPLIANCE DIAGNOSTICS?

Durrus Compliance Diagnostics

Durrus Compliance Diagnostics is headquartered in Cork, Ireland. It is a University College, Cork (UCC) spin-out company set up to commercialise the AML Maturity Model Suite© which includes the AML Cultural Diagnostic (AML-CD), the AML Performance Diagnostic (AML-PD), and the AML Directors Diagnostic (AML-DD).

WHAT IS THE AML MATURITY MODEL SUITE©?

AML Maturity model Suite

The AML Maturity Model Suite© was the result of many years’ research by an expert team at University College Cork (UCC) in conjunction with an Industry working group.  The research was funded by Irish government development agencies within a national centre for financial services research.

The AML Maturity Model Suite© includes the AML Cultural Diagnostic (AML-CD), the AML Performance Diagnostic (AML-PD), and the AML Directors Diagnostic (AML-DD).

WHAT IS THE AML CULTURAL DIAGNOSTIC (AML-CD)?

AML Cultural Diagnostic

What is it?

The AML-Cultural Diagnostic is a rapid way to measure AML culture and to create an internal benchmark of cultural embedding across different parts of your business.

How is it conducted?

The AML-Cultural Diagnostic surveys staff anonymously using the Qualtrics web based survey tool. A web link or URL is distributed by email to all employees included in the survey.

What is the methodology that it uses?

The AML-CD takes a new approach to measuring culture by applying techniques used by NASA to measure intangible concepts such as culture. The AML-CD asks a series of judgement questions across seven cultural performance factors that examine whether the prevailing behaviours and attitudes embed the spirit of the law and best practices into the organisation.

What are the seven Cultural Performance Factors that are measured?

The seven factors that are measured are Leadership, Communications, Training, Policies & Procedures, Rewards & Recognition, Ownership, and Resources.

How long does the diagnostic take to complete?

The diagnostic should take approximately 15 minutes to complete but participants are also invited to provide their own comments / feedback so this will lead to more time. There should be no disruption of, or impact upon, normal business.

What format does the AML Cultural Diagnostic take?

The AML-CD consists of 28 judgement questions across the 7 cultural performance factors.  A further small number of client specific ‘demographic’ questions are asked at the end of the survey. These demographic questions are designed to protect the respondent’s anonymity but facilitate deep dive analysis that will deliver in-depth information for areas of critical interest. Respondents are also given the opportunity to provide free-text commentary.

How do we determine the target audience for the AML Cultural Diagnostic?

As many staff as possible across all areas touched by AML should be targeted. We recommend that a minimum of 70% of relevant employees should actually complete the diagnostic.  All levels of responsibility should be represented including an appropriate target profile which includes representation from the highest levels (up to and including board level) in the organisation.

How is the diagnostic distributed?

Durrus issues a client specific URL which is then embedded by the end client in an email for distribution to the intended respondents.

How are the AML Cultural Diagnostic results presented?

Using the demographic data the results can be presented at a number of different levels.

  • A thematic review of free text commentary.
  • An overall organisational view which consists of an aggregated roll-up of the quantitative analysis of the organisation’s AML culture presented as a single pictorial visualisation.
  • Detailed analysis of each of the 7 cultural embedding factors cross-referenced with the thematic review.
  • Deep-dive drill down into areas identified by the organisation as being of critical interest.
  • Comparative analysis leading to an internal benchmark. E.g. One organisational grouping versus another organisational grouping.

In short, what can the AML-CD do for my organisation?

The AML-CD can rapidly and cost effectively provide a Measurement of your AML culture and an Internal Benchmark of cultural embedding across your business. It tells you whether:

  • Tone at the top is fully disseminated through the organisation.
  • Leadership & management prioritise AML as business critical.
  • Processes are guiding the right AML behaviours.
  • Resourcing of People & Technology adequately support AML compliance.
  • Training is fit for purpose and empowers the right AML behaviours.
  • Constructive dissent is expected and strongly encouraged.
  • Ownership of AML is seen as both a personal & collective responsibility.
  • Rewards & Penalties are encouraging good AML behaviours.
  • Whistleblowing process is something staff see as effective & are willing to use.

Can I see a demo of the AML –CD?

Yes. A short online demo of sample questions from the AML-CD can be provided along with sample output. Please contact us with your details.

What steps should a client take to prepare for a successful AML-CD?

  • Identify a team of appropriate champions to push the diagnostic out across the business.
  • Develop an appropriate communication plan.
  • Agree client specific demographic questions.
  • Review the survey questions to determine whether any client specific language / terminology changes are required.
  • Confirm whether the client side IT security team expects a 3rd party Information Security & Cyber Security Questionnaire to be completed.
  • Develop a distribution plan to include who will distribute the diagnostic and when it should be done.
  • It is advisable to run a test across a small number of recipients in each of the geographical locations to ensure there are no technical / firewall issues.
  • Agree on required reports.
  • Establish firm start and end dates.
WHAT IS THE AML PERFORMANCE DIAGNOSTIC (AML-PD)?

AML Performance Diagnostic

What is it?

The AML-Performance Diagnostic is a rapid way for an institution to self-assess the completeness and the capability of their AML control structures and identify AML process strengths and weaknesses.

How is it conducted?

The AML-Performance Diagnostic is used to survey compliance officers and their teams using the Qualtrics web-based survey tool. A web link or URL is distributed by email to relevant employees included in the survey.

What is the methodology that it uses?

The AML-PD leverages the process maturity modelling approach pioneered by the Software Engineering Institute (SEI) of Carnegie Mellon University in the US, which has now found its way into many other domains and applications. The AML-PD asks participants to rate their AML capability using a series of 44 questions distributed across key AML business process areas that objectively examine the essential practices and process assets required for good AML performance.

What are the Process Performance Areas that are examined?

The key AML business process areas that are examined are:

  • AML Governance
  • AML Risk Assessment
  • AML Due Diligence
  • AML Investigation & Reporting
  • Organisational Supports for AML

How long does the diagnostic take to complete?

The diagnostic should take approximately 2 hours to complete but participants are also invited to record evidence in support of the ratings or to provide their own comments / feedback so this will lead to more time.

How is the diagnostic distributed?

Durrus issues a client specific URL which is then embedded by the end client in an email for distribution to the intended respondents.

How are the AML Performance Diagnostic results presented?

  • An overall organisational view which consists of an aggregated roll-up of the ratings awarded by each participant presented as a single pictorial visualisation.
  • Detailed analysis of each of the 17 AML Process Areas for each respondent including any evidence that was recorded in support of the individual ratings awarded for each of the 44 questions.
  • Comparative analysis of the individual scores awarded by the participants enabling the identification of gaps in the AML control structures or compliance team knowledge.

In short what can the AML-PD do for my organisation?

The AML-PD can rapidly and cost effectively give the organisation and its board the assurance that the bank is maintaining an effective AML control structure. In particular it:

  • Provides an overall assessment of AML compliance capability in a matter of hours.
  • Helps prepare institutions for regulatory inspections or engagements.
  • Accelerates remediation planning and re-design.
  • Provides key inputs to MLRO reports.
  • Enables effective prioritisation and utilisation of resources for AML work programmes.
  • Enables benchmarking and goal setting.
  • Facilitates deep-dive investigations of business critical processes.
  • Provides assurance that AML processes will guide the right AML behaviours.

Can I see a demo of the AML–PD?

Yes. A short online demo of sample questions from the AML-PD can be provided along with sample output. Please contact us with your details.

What steps should a client take to prepare for a successful AML-PD?

  • Identify a champion to have ownership of the diagnostic for the business and who will act as a point of contact and distributor of the survey.
  • Communicate with the participants for their awareness, availability, and preparedness.
  • Review the survey questions to determine whether any client specific language / terminology changes are required.
  • Confirm whether the client side IT security team expects a 3rd party Information Security & Cyber Security Questionnaire to be completed.
  • It is advisable to run a test in each of the geographical locations to ensure there are no technical / firewall issues.
  • Agree on required reports.
  • Establish firm start and end dates.
WHAT IS THE AML DIRECTORS DIAGNOSTIC (AML-DD)?

AML Directors Diagnostic

What is it?

The AML-Directors Diagnostic is a way for board members and senior executives to rapidly appraise their individual understanding of their institution’s AML framework for managing Anti-Money Laundering compliance risk.

How is it conducted?

The AML-Directors Diagnostic uses an on-line questionnaire based upon the Qualtrics web-based survey tool accessed via a web link or URL. The questionnaire is for the individual’s own use and is not required to be returned to anyone.

What is the methodology that it uses?

The AML-DD leverages methodologies developed by Durrus Compliance Diagnostics for assessing AML process performance that has been specifically adapted for board members and senior executives. The AML-DD asks participants to appraise their individual understanding of their organisation’s AML framework by answering a series of 35 questions for key AML business process areas.

What are the areas that are covered?

The key AML business areas that are covered are:

  • AML Governance
  • AML Risk Assessment
  • AML Due Diligence
  • AML Investigation & Reporting
  • Organisational Supports

How long does the diagnostic take to complete?

The diagnostic should take approximately 1 hour to complete but participants also have the facility to record their own personal notes and observations which could lead to more time being required.

How is the diagnostic distributed?

Durrus issues a client specific URL which is then embedded by the end client in an email for distribution to the intended respondents.

How are the AML Directors Diagnostic results presented?

Each respondent can print off their own personal responses to the diagnostic and could, for instance, use the results to identify specific areas of AML where they would like annual training to focus on.

In short what can the AML-DD do for boards and senior executives?

  • It enables boards and senior executives appraise their individual understanding of their organisation’s overall framework for managing AML compliance risk.
  • It enables boards and senior executives to effectively and appropriately challenge their organisation’s approach to managing money laundering risk, including when papers are presented for their review and approval.
  • It enables boards and senior executives prepare for AML training by allowing them to focus on specific areas of the framework where they would like to enhance their knowledge of money laundering risk management within their firms.

Can I see a demo of the AML–DD?

Yes. A short online demo of sample questions from the AML-DD can be provided along with sample output. Please contact us with your details.

WHERE ARE THE AML DIAGNOSTICS DATA HOSTED?

All responses will be hosted securely and anonymously by Durrus Compliance Diagnostics in Qualtrics data centres which are trusted data centres that are independently audited using the industry standard SSAE-16 method.

Where are the aml Diagnostics data hosted?

WHAT ARE THE TECHNICAL REQUIREMENTS OF THE AML DIAGNOSTICS?

What are the technical requirements of the aml diagnostics?

The diagnostics sit on Qualtrics which is an Application Service Provider (ASP) using a Software-as-a-Service (SaaS) platform for creating and distributing online surveys.  All services are online and require no downloadable software; only modern JavaScript-enabled internet browsers are required (no Java/JVM or Flash).  Internal firewall conditions may need to be updated to allow access to the Qualtrics host.

WHO HAS DURRUS WORKED WITH?

Who has durrus worked with?

Durrus has worked with Irish and international clients which include:

 

                 

WHAT DO PREVIOUS CLIENTS SAY ABOUT OUR DIAGNOSTICS?

What do previous clients say about our diagnostics?

  • “There was no disruption of or impact upon normal business; implementation was seamless.”
  • “The exercise made the staff fell more involved in the AML process and allowed them the opportunity to provide feedback on AML-related processes which are relevant to their daily work.”
  • “We now believe we have an accurate measure of the AML culture within the bank, something we previously felt but could not easily demonstrate.”
  • “The Bank’s Financial Crime Compliance team was impressed with the seamless implementation and completion of the project with no variance in end-user experience in any of the multiple locations.”
  • “The Bank’s Financial Crime Compliance management team stated that the AML-CD was a positive experience. It validated for them that their previous investment in the new cross-jurisdictional AML framework was embedding the right behaviours in the organisation. It identified specific areas of improvement that would further complement and strengthen the new FCC framework.“
  • “The performance and cultural diagnostic proved itself to be immensely powerful in summarizing, in a consistent and concise fashion the capability level of the Bank. The results truly became real to us as they independently reflected what we observed on the ground.”
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