From 1 July 2018, most lawyers are captured under the AML/CFT Act  and therefore have several AML/CFT requirements.  These requirements include:

• Appointing a compliance officer;
• Conducting a Risk Assessment;
• Developing an AML/CFT Programme based on the Risk Assessment;
• Keeping AML/CFT documents up-to-date;
• Conducting Customer Due Diligence;
• Regular staff training on AML/CFT;
• Annual reporting on AML/CFT to the DIA; and
• AML/CFT Audit every two years, which involves having the Risk Assessment and Programme audited by an independent auditor(the first audit must be conducted before 1 July 2020) 

We highlight the obligation to arrange an AML/CFT Audit, before 1 July.  Although the AML/CFT Supervisors have given some relief with verification, they have not yet announced timing changes to the audit requirement.   

Now is an opportune time to arrange an independent AML/CFT audit, even if it needs to be delayed.

Contact us to discuss an audit.