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The AML CULTURAL DIAGNOSTIC (AML-CD)

 

BACKGROUND

The AML-CD leverages the “Goal, Question, Metric” approach which was originally defined for use by NASA at their Goddard Space Flight Centre to measure if goals expressed at a conceptual level were actually being attained. We have adapted this approach to assess the behaviours and attitudes that determine the prevailing culture for AML compliance.

HOW IT WORKS

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.

HOW ITS DELIVERED

The diagnostic is delivered as an on-line survey and takes approximately 15 minutes to complete. Data is captured anonymously but with enough definition that subsequent deep-dive analysis can be conducted without compromising individual anonymity. Respondents are also given a number of opportunities to provide free-format commentary. There is very little or no IT or HR support required and Durrus Compliance Diagnostics can provide daily reports on uptake across the institution so that targeted communications can be issued as needed.

Results

Preliminary quantitative results can be available almost immediately after the AML-CD being closed off with fuller detailed analysis of both quantitative and qualitative results following very soon afterwards. Detailed analysis is typically presented at three different levels

  • An overall macro-level organisation view providing an aggregated roll-up of the institution’s AML culture across its whole business.
  • A detailed individual analysis for each of the cultural performance factors cross-referenced with thematic analysis of the comments received.
  • Deep-dive assessment of individual areas of critical interest to cultural embedding.

Benefits

Executing the AML-CD provides institutions with a range of fantastic benefits and enables them to greatly enhance understanding of their culture in respect of AML compliance and to evaluate whether:

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

The AML PERFORMANCE DIAGNOSTIC (AML-PD)

BACKGROUND

The AML-PD came about through our foundation research into modelling AML process capability. It 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. We have adapted the maturity model method to identify the key processes essential for good AML practice. The AML-PD is typically deployed to MLRO’s compliance officers and their teams.

HOW IT WORKS

The AML-PD asks participants to rate their AML capability using a series of questions distributed across 17 key process areas. To help the participant make an objective rating the activities and resources that should be available are described. The participant is asked to consider the extent to which these criteria are preformed or are available in their institution before awarding a rating. Rating guidelines are provided and the participant also has the opportunity to record free format commentary for any of the questions.

HOW ITS DELIVERED

The diagnostic is delivered on-line and takes approximately 2 hours to complete. Data is captured as a series of ratings for each of 44 questions that are distributed across the 17 process areas. There is very little or no IT or HR support required.

Results

A results report can be available almost immediately after the AML-PD is closed off. The report presents a comparative analysis of the ratings given by each respondent and any commentary they recorded. The report can then be used by the compliance team to frame a discussion on the scores that individuals awarded, their justification for their scores, and identify opportunities to enhance AML processes and supporting documents or technologies.

Benefits

Executing the AML-PD provides institutions with a range of excellent benefits and enables much greater understanding of the institutions processes, documentation and technologies for AML compliance. In particular it:

Is fast, cost effective and end-to end.
Provides an overall self-assessment of AML compliance capability.
Accelerates remediation planning.
Helps prepare for regulatory inspections.
Provides key inputs to MLRO reports.
Facilitates deep-dive investigations of business critical processes.

The AML Directors Diagnostic (AML-DD)

BACKGROUND

Board members carry a personal liability for ensuring compliance with AML requirements. Which raises the question: “How does a board member or senior executive appraise their understanding of their institution’s AML framework?”.  We created the AML-DD to solve this problem. Board members and senior executives can use the AML-DD to rapidly self-assess their understanding of how their institution manages Anti-Money Laundering compliance risk.

HOW IT WORKS

The AML-DD presents the participant with a series of 38 questions distributed across 17 key areas for AML. The participant is requested to rate their practical level of knowledge concerning the substance of each question and thereby identify particular aspects of AML where they would benefit from training or review. The questionnaire is for individual self-assessment. Rating guidelines are provided and the participant also has the opportunity to record notes for their own use.

HOW ITS DELIVERED

The diagnostic is delivered on-line and takes approximately 2 hours to complete. Data is captured as a series of ratings for each of 44 questions that are distributed across the 17 process areas. There is very little or no IT or HR support required.

Results

A results report is available immediately after the AML-DD is closed off. The report presents a summary of the ratings recorded by the respondent plus any notes made. The report can be used by the respondent to highlight areas of the AML framework where they feel they need more familiarisation or training.

Benefits

The AML-DD provides board members and senior executives with an objective way of assessing their knowledge about their institutions AML framework. In particular it:Enables rapid appraisal and reassurance of individual understanding of the AML framework.
Identifies AML training needs by focussing on specific areas of the AML framework.
Enables senior managers challenge the institutions approach to ML risk management.
Helps board level preparations for regulatory inspections.