Off-site Monitoring

The Off-Site Monitoring Division is responsible for performing the following duties across the four (4) sectors we supervise:

• The issuance of questionnaires to the entities
• Risk rating of the DNFBPs
• Ensuring that Action Plans from the On-Site Examinations division are addressed by the DNFBPs
• Performing Desk Based Reviews
• Conducting outreach sessions for the DNFBPs
• In-house training of the DNFBPs
• Registration of the DNFBPs

The Issuance of Questionnaires

The supervision process starts with the issuance of questionnaires to:

1. Accountants,
2. Attorneys,
3. Dealers in Precious Metals and Stones and
4. Real Estate Agents.

All businesses within these sectors are required to complete a questionnaire to first determine whether they are a DNFBP and secondly to start the supervision process if they are a DNFBP.

Risk Rating of DNFBPs

Once a questionnaire has been completed, the risk rating process is started.  This risk rating process results in a rating being assigned to each DNFBP which determines whether the entity will be subject to an On-site Examination or a Desk Based Review.  The On-Site Examination is a more detailed process than the Desk Based Review.

The Action Plan Follow-Up Process from On-Site Examinations

After the On-Site Examination Division has completed an examination, an Action Plan is issued by the Off-Site Monitoring Division.  This Action Plan contains action items which detail the deficiencies found during the On-Site examination.  Each action item must be addressed for the DNFBP to exit the follow-up process.

Once the DNFBP has exited the process members of the On-Site Examinations and Off-Site Monitoring teams perform a brief review to ensure that the entity is adhering to its policies and procedures.  Subsequently, a re-rating of the entity is performed.

Desk-Based Reviews

Desk-based reviews are less extensive reviews of the entity’s policies and procedures.  They involve reviewing the same areas which are reviewed for an On-Site examination but actual client files are not examined during the review.

Outreach Sessions

From time to time the Unit conducts outreach sessions, with the assistance of both departments, which are aimed at sensitizing the DNFBPs of their duties where AML/CFT/CPF compliance is concerned.  Further information on these sessions can be found by clicking here.

In-house Training

The Off-Site Monitoring Division will be conducting in-house training sessions for the DNFBPs.  These sessions will involve an overview of the requirements of entities where AML/CFT/CPF compliance is concerned.  For more information on how you can benefit from these sessions please contact us.

Registration of the DNFBPs

The Off-Site Monitoring Division will also be responsible for the registration of the DNFBPs with the Compliance Unit.  Once started, the registration process will involve submitting information about your business to the Compliance Unit.

On-site Examinations

The On-site Examinations Division carries out a key element of supervision and that is to examine and assess the entity’s AML compliance program.

The requirement for the examination is based on the level of risk which is assessed for each entity. The frequency of subsequent examinations will be 1 – 3 years depending on the entity’s risk profile which draws on standard risk factors.

The On-site examination has two main components:

• The evaluation of the entity’s anti-money laundering compliance program, which will include reviewing the effectiveness of the entity’s risk assessment, AML policies and internal controls.

  The On-site Compliance Officers will interview the key officers responsible for AML and interviews may be conducted either in person or virtually.

• The inspection of a sample of AML records and documents related to the entity’s AML procedures.

  The officers will therefore require the requisite level of access to all the records and paperwork related to your AML procedures.