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Thematic programme examinations in 2021


In November, we published our programme of thematic examinations for early 2021. We are now publishing our thematic programme for the remainder of the year 2021.

Our Supervision Examination Unit (SEU) will undertake two further thematic examinations in Q2 and Q3 2021.

Customer risk assessments

The first of these will focus on customer risk assessments. This is a result of a number of findings which continue to be identified through our examination programme. It also links to the recommendations from the National Risk Assessment (NRA), particularly the Trust and Company Services Provider chapter.

The examination’s primary focus will be on testing how well businesses obtain information for assessing the risks of money laundering and the financing of terrorism, as well as establishing how well that information is evaluated once gathered.

Monitoring of customer relationships and transactions

In Q3, the SEU will focus on the ongoing monitoring of customer relationships and transactions.

This examination will test the systems and controls in place that enable businesses to scrutinise transactions and ensure they are consistent with their knowledge of the customer. It will also look at how businesses keep documents, data or information up to date and relevant by undertaking reviews.

These examinations will consist of two elements. A questionnaire will be issued to a number of organisations, with more in depth examinations taking place at selected businesses.

Legal sector

Our Pooled Supervision Unit will also undertake a thematic examination of the Legal Sector in Q2 and Q3 of 2021.

The scope of the examination will include client risk assessments, use of client accounts, suspicious activity reports, employee training and knowledge and the effectiveness of compliance systems and controls; all of which are areas highlighted in the NRA.

We will be hosting a webinar on our approach to examinations on Wednesday 24 March at 14:00. Monitor our website and social media for further updates.