ARROWS conducted an FAO audit for the client and strengthened its AML system
ARROWS Law Firm provided legal support to a client during an inspection by the Financial Analytical Office focused on compliance with AML obligations. The key was to quickly assess the actual state of internal processes, respond appropriately to the regulatory authority’s requests, and simultaneously minimize the risk of penalties. As a result, the client successfully navigated the inspection without any significant impact and strengthened its AML system for the future.
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After commencing the audit, ARROWS analyzed how the client was fulfilling its obligations in practice regarding customer identification and verification, risk assessment, verification of beneficial owners, and the retention of AML documentation. The chosen strategy consisted of a combination of substantive procedural defense and the rapid supplementation of those parts of the documentation and internal procedures that needed to be clarified or standardized. This approach was the most appropriate in this case because it allowed us to demonstrate that the client was in fact fulfilling its AML obligations while simultaneously addressing specific weaknesses during the course of the inspection.
ARROWS subsequently prepared materials for communication with the Financial Intelligence Unit (FAÚ), amended selected internal regulations, and established a clearer system of record-keeping and accountability for the client regarding AML matters. The solution also included addressing the audit findings and preparing arguments in case of subsequent administrative proceedings. The audit was thus concluded with minimal impact, and the client obtained a functional AML framework that will stand up to further regulatory review.