Effectiveness Of The Company s Internal Controls Over...

1. BACKGROUND INTRODUCTION AND SCOPE 1.1 BACKGROUND The overall objective of this review is to provide opinion on the effectiveness of the Company’s internal controls over Anti Money Laundering risk management systems and reporting following concerns identified by Compliance over the efficacy of those controls. This report has been produced to enable Senior Management to assess current risk. This guidance promulgates an approach by which management can conduct a top-down, risk-based evaluation of internal systems and controls. An evaluation that complies with this report is one way to satisfy the evaluation requirements of Rule 3.2.6 of the SYSC sourcebook of the Financial Conduct Authority (FCA) and the Prudential Regulatory Authority (PRA) Handbooks. Appendix 1 1.2 INTRODUCTION Under the UK regulatory system, Senior Management are responsible for maintaining a system of internal control over financial crime that provides reasonable assurance regarding the reliability of the systems and controls DI has in place for the detection and prevention of financial crime. To gauge whether a system is â€Å"appropriate,† or whether â€Å"reasonable measures† have been taken, requires an assessment of risk. Compliance designs, implements, tests and monitors the framework of the risk management process used to identify and manage risks in accordance with DI’s risks appetite. A system of effective internal controls is a critical component for a sound operation. 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