AML, Compliance and Governance

Effective policies and procedures are central to a strong compliance framework. We help clients review, assess and draft clear, practical documentation that reflects their obligations, risk profile and operating model, including AML/CFT/CPF, due diligence, sanctions, SAR/STR, training and retention policies.

Key Deliverables
Policy gap analysis, updated policies or newly drafted procedures, together with practical recommendations to support implementation and day-to-day use.

A well-documented risk assessment helps evidence a company’s risk-based approach and supports proportionate decision-making as well as comply with a company’s regulatory requirements. We help review, refresh or draft Business Risk Assessments and related AML, financial crime or compliance risk assessments, identifying key risks, controls and mitigating actions.

Key Deliverables
A reviewed or drafted Business Risk Assessment or risk assessment review report, including observations, identified gaps and recommended improvement actions.

Clear compliance and MLRO reporting supports effective governance, oversight and decision-making. We help clients prepare or review Compliance Reports and MLRO Reports so that key matters are presented in a structured, evidence-based way.

Key Deliverables
Drafted or reviewed Compliance Reports and MLRO Reports, with supporting observations, suggested enhancements and clear reporting structure.

For relevant firms, an independent audit function is a requirement under section 26(1A) of POCA and provides an important opportunity to assess whether AML/CFT/CPF arrangements remain effective, proportionate and appropriately documented. An independent review brings objectivity, challenge and specialist experience that may be difficult to achieve through an internal review alone, particularly where internal teams are close to the controls being assessed. We provide an objective review of the client’s framework, policies, procedures and controls against relevant POCA requirements and regulatory expectations. See our Internal Audit section for more information: https://www.pwc.gi/services/audit-internal.html

Key Deliverables
An independent audit report setting out the scope of work performed, key findings, control observations, recommended actions and areas for remediation or enhance

Regulatory expectations continue to evolve, and Directors /companies need confidence that their compliance arrangements remain aligned to local requirements. We assess policies, procedures and wider compliance frameworks against relevant POCA requirements and GFSC Guidance Notes, helping identify gaps and prioritise practical improvements.

Key Deliverables
A structured gap analysis and action plan setting out areas for attention, recommended improvements and prioritised remediation steps.

When issues are identified, prompt, clear and practical remediation is key. We help clients respond to findings from internal reviews, external reviews, regulatory feedback, audits, gap analyses or control weaknesses by turning those findings into prioritised actions that can be tracked and implemented. This can include regulator readiness reviews to help clients assess preparedness and identify practical areas for improvement.

Key Deliverables
Prioritised remediation support, action plans, progress tracking input, regulator readiness review feedback and practical guidance to help address identified gaps and strengthen the control environment.

Clients often need practical support in applying AML, compliance or UBO requirements to specific facts, structures or risk scenarios especially for newly appointed MLROs or companies with less developed Compliance function. We provide subject matter input, second views, critical friend support and on-demand advisory input, including assistance with UBO identification in more complex ownership or control arrangements.

Key Deliverables
Advisory input, practical guidance, position papers or on-demand critical friend support to inform decision-making on AML, compliance or UBO-related matters.

Sanctions compliance requires clear ownership, effective screening, escalation processes and documented decision-making. We help clients review sanctions policies, procedures and controls, assess alignment with regulatory expectations and identify practical improvements across governance, screening, alert handling, ownership and evidence retention.

Key Deliverables
Sanctions framework review, gap analysis, policy or procedure updates, escalation process enhancements and practical recommendations to strengthen sanctions governance and control effectiveness.