What needs to be clarified
The analysis could compare the agreed document set with the actual process and identify changes for an ongoing support plan.
Materials to prepare
- A description of the business, new sales channel and transaction structure.
- Current internal documents and allocation of responsibilities.
- Anonymised examples of requests moving through the process and recurring questions.
What to compare
- Which process stages have appeared or changed.
- Where documented procedures and staff actions diverge.
- Which tasks fall within the agreed support scope.
Possible outcome of the analysis
A possible output is a list of discrepancies and an improvement plan with responsible roles, agreed tasks and a method of recording completed work.
Limits of the conclusions
Acting as the designated AML officer and submitting reports are not automatically included and require separate agreement; no guarantee is given that a bank or supervisory authority will raise no objections.