AML/CFT audit function

The AML/CFT places an obligation on financial institutions, trust agencies and business service providers to have a AML/CFT audit function



effective and independent

The Money Laundering and Terrorist Financing (Prevention) Act (also referred to as Wwft in Dutch) obliges financial institutions, trust agencies and business service providers to have a Wwft audit function, to the extent appropriate to the nature and size of the institution. This audit function checks the organisation’s compliance with the AML/CFT, including the performance of the compliance function in this context.

The auditing function should be set up as independently as possible. However, this is not always easy in practice, especially for smaller companies. Therefore, more and more organisations are choosing to outsource their AML/CFT audit function.

How we work
with you

Projective Group handles the AML/CFT audit function for various financial institutions. But we also support accountancy firms, lawyers, and notaries. We understand that each client’s situation is unique, and a ‘one size fits all’ approach cannot work. We consider the nature, size, and maturity of each organisation. This is why we always begin the audit process with a quick scan to assess your situation and the maturity of the compliance function.

Then, based on what we discover, we work with you to create a risk-based audit plan for the year.
As an auditor, we check compliance with the AML/CFT. More specifically, we assess the following criteria:

  • Compliance Function and Monitoring: The performance of the compliance function, in particular the implemented compliance monitoring activities.
  • Policies, Procedures, and Measures: The policies and procedures you have in place, and whether they are up to date
  • Supplementary Activities: Optionally, we make independent observations on client files and the transaction monitoring process

We record our findings in a clear and concise report. We can also advise you how to make improvements for the future, ensuring that you meet regulatory guidelines and achieve long-term compliance. If desired, we can keep you informed about the developments in relevant regulatory changes via our regulatory updates.

Independent Judgement

Curious to know whether your organisation requires a Wwft audit function? Our AML/CFT specialists are here to help you figure that out. Even if having an AML/CFT audit function is not mandatory for your organisation, having one in place can be of added value

We can assess things like your CDD and transaction monitoring process, and even help to prepare you for any regulatory investigations. It is all about giving you an independent perspective – an honest and impartial point of view.