The Annual Anti Money Laundering Compliance Officer (AMLCO) Report is an annual reporting obligation for regulated entities who offer investment, crypto-asset, and payment services. Essentially, this report analyses issues regarding Anti Money Laundering and Countering the Financing of Terrorism (AML/CFT), as well as measures and controls employed the preceding year.
Findings and Recommendations
The findings and recommendations outlined in an AMLCO Annual Report are fundamental for evaluating the efficiency of a Company’s AML/CFT established procedures. The exposure of the findings pinpoints weaknesses and gaps within the Company’s AML/CFT framework, including deficiencies in policies, controls, or employee training. Therefore, pointing out these deficiencies would enable the Company to remedy such shortcomings by adopting necessary measures to strengthen its ML/TF risk. Furthermore, such reports evaluate compliance with AML regulations such as Customer Due Diligence and the reporting of Suspicious Activities. Recommendations for addressing issues to be resolved are provided by the AMLCO to ensure that the organization meets their regulatory obligations effectively.
Additionally, the AMLCO within his task to inspect the Company’s compliance, conducts risk assessments to identify and evaluate risks associated with the entity’s business activities and customers. Evaluating the effectiveness of internal controls, such as transaction monitoring systems and customer screening processes, is crucial for mitigating AML/CTF risks. In this regard, the objective of the AML training program is to ensure that employees have a better understanding of AML/CFT. Therefore, they will be in a better position to identify suspicious transactions that might involve Money Laundering. Entities that adopt the recommendations made by the AMLCO in his annual report shall be able to reduce their risk of non-compliance with regulatory requirements.
CySEC's Circular C516
]The CySEC Circular C516 provides guidance relating to the AML/CFT obligations for entities under its supervision. The guidance provided focuses on the weaknesses identified through the annual assessments conducted on AMLCO reports received. Additionally, Circular C516 serves as a reminder of the regulated entities’ key reporting obligations, such as the Internal Audit Reports and the relevant Board of Directors minutes. The Circular also expresses the need for regulated entities to implement policies, procedures, and controls tailored to the Company’s specific risk profiles. Furthermore, it stresses the importance of ongoing monitoring and updating of these measures to adapt to evolving threats and regulatory standards.
Moreover, Circular C516 analyzes the responsibilities of AMLCOs within regulated entities. It summarizes their duties, including but not limited to overseeing the implementation of AML/CFT measures, conducting risk assessments and establishing the AML Monitoring Program. Additionally, it provides guidance on the preparation and submission of the AMLCO Annual Report, highlighting the essential information to be included and the process for review and approval by the Board of Directors before submission to the Regulator.
What is the Annual AMLCO Report course and what does it include?The
Annual AMLCO Report course, is developed by
SALVUS Funds and led by their Risk & Compliance Director,
Evdokia Pitsillidou. Evdokia focuses on presenting the key areas any AMLCO Report shall be comprised of, along with a detailed explanation on how to study, review and present the information gathered.
The course is designed to assist employees assigned with the construction of the AMLCO Annual Report for the year 2024. It furnishes them with thorough guidance on the necessary information to be incorporated. Additionally, it aids Board of Directors members in examining and assessing the report prior to its presentation to the regulatory body. The SALVUS Regulatory Compliance team possesses extensive expertise in preparing annual reports for regulated entities operating in investment, cryptocurrency, and payment sectors. This course draws upon their first-hand knowledge to present the process of preparing the Annual AMLCO report.
The syllabus of the Annual AMLCO Report course includes:
- Introduction on how to prepare the AMLCO Annual Report
- Obligation, Purpose & Significance
- Timeline & Reference Period
- Submission to the Board of Directors
- Board of Directors minutes
- Submission to CySEC
- Contents of the Report - CySEC Circular C516 - Findings of the AMLCO Annual Reports' Assessment
- CySEC Circular C516
a. Weaknesses
b. Reminders
- Reporting Tips - The Annual AMLCO Report; Executive Summary
- Characteristics
- Structure
- Findings & Recommendations
- The AMLCO Annual Report; Company Information, Regulatory Framework & the AML Department
- The Company
- Regulatory Framework
- The AML Department
- The AMLCO Annual Report; AMLCO's Inspections, desk-based and onsite
- AMLCO Inspections
a. Rectified Findings
b. Findings & Recommendations
- Regulator Inspections
- The AMLCO Annual Report; Reporting, Monitoring and Communication
- Suspicious Transaction Reporting
- Internal Reporting
- External Reporting
- Cash deposits
- High-risk customers
- Business Divisions
- Internal Controls
- Monitoring Plan
- Branches & Subsidiaries outside EEA
- Communication, Education and Training
The material of the course is delivered in PDF slides and online video recordings. Learners registered for this course are provided with the flexibility to learn wherever and whenever.
Upon completion of the course, learners have the opportunity to assess the knowledge acquired by answering a series of questions based on the examined material.
