AML/CTF Risk Assessment and Control Plan: Business Solution Limited

This report provides a comprehensive AML/CTF risk assessment for Business Solution Limited (BSL) considering the acquisition of Frontline Financing (FF). It outlines risk factors such as money laundering, terrorism financing, and loss of intellectual property. The assessment utilizes tools like customer profiling, product analysis, channel evaluation, and country risk assessment. The report details risk criteria, measurement, and treatment, including risk monitoring and control mechanisms. It also explores industry typologies, BSL's risk appetite, and vulnerabilities related to online trade financing and offshore operations. The report concludes with a discussion of the need for a robust monitoring system and adherence to regulations, emphasizing the importance of initial and ongoing AML/CTF controls, stakeholder consultation, and a review of ML/TF assessment.

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Anti-money laundering and terrorism financing
University name
Word count

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Introduction
The organization considered in this paper is Business solution Limited that provides over the
counter finance for businesses (Alexeev, 2018). This paper aims to prepare a document for
the board of BSL related to the acquisition of Frontline Financing (FF) which deals with
online trade financing as a major service (Amor et al., 2016). The frontline financing is the
first offshore investment to be considered by BSL as it is confined to Australia only as of
now (Anthopoulos, 2016). As a consultant regarding the AML/CTF, risk assessment
methodology is provided in this paper (Bakumenko & Sigal, 2018). The Frontline Financing
is an entity of New Zealand which is regulated under Anti-money laundering and countering
financing of Terrorism Act, 2009 (NZ)
Risk assessment methodology
Risk factors
a) Loss of potential customer due to rigorous identification procedures
b) Loss of intellectual property rights to competitors
c) Loss of market to new entrants
d) Money laundering by fraudulent means
e) Terrorists funding through hawala transactions
Risk criteria
The criteria to be considered to assess the risk are as follows:
1. What is the transparency level of financial operations conducted by FF- good, bad or
excellent?
2. How much amount goes to countries providing a haven to terrorists and associated
organizations/
3. What is the disclosure level of FF to the Government of New Zealand and other
international financial institutions concerned with money laundering and terrorist financing?
4. Is there a sound record of money traded online by FF?

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Tools to be used in the risk assessment
There are 4 tools to be used
Risk identification-
 Customer- For the purposes of assessing the inherent money laundering risk of a
business division, unit or business line, the client base and business relationship
should be assessed.
 Product- Increasingly complex product offerings complicate risk assessment
activities, as these offerings, by their very nature, are more difficult to assess than
traditional banking products and services.
 Channel- online account openings present challenges in verifying the account holder's
true identity and geographic origin or business footprint; All these issues affect an
institution's ability to predict the type and frequency of transactions the customer is
likely to make; without a firm understanding of the customer's risk profile,
monitoring for suspicious activity and, by extension, the reporting of suspicious
activity can be more challenging.
 Country- Geography/Country risk will be important in any Sanctions Risk
Assessment, not only with respect to sanctioned countries themselves, but also those
which may have well known/important links or other significant connections to
sanctioned countries
Risk assessment and measurement
The likelihood of risk is severe with score of 5 is given in below table. The major risk of
money laundering and counter-terrorism is the most important risk to be carried on the
platform leading to severe consequences for whole BSL team.
Risk treatment
The risk of AML/CF is to be treaty on priority basis to deal with all compliance rules and
regulations. There will be sophisticated development and use of technology to identify
AML/CF activities.
Risk monitoring and control
The safety audit will be conducted after 1 year to assess the impact of safety measures. Apart
from this, the mid-year review will be taken after 6 months by senior managers. The
contingencies will be planned and dealt with readily.
Risk assessment and measurement
Risk Size Importance Likelihood Impact Score (1-5)
Backlash
from
Small Less important Less Moderate 2

4
nationalists
Money
laundering
activities
Big Very
important
High severe 5
Terrorism
financing
Big Very
important
High severe 5
Loss of
intellectual
property
rights
Moderate Important Moderate Severe 4
Loss of
market due
to newbies
Moderate Moderate Moderate moderate 3
Risk treatment
Business risks- Business risk can have an impact on operational risks and contribute to an
increasing or decreasing likelihood of breakdowns in key AML controls. For example,
significant strategy and operational changes, such as the introduction of a major new product,
or service, a merger or an acquisition, opening in a new location or closing an entity may
affect the inherent risk. These changes may well require a review of existing, or the
establishment of new, internal controls, and given that these controls may take some time to
become effective, the division, unit or business line will need to assess whether the inherent
risk may have temporarily increased or changed
Regulatory risks- Regulatory Risk is generally defined as the risk of having the 'licence to
operate' withdrawn by a regulator, or having conditions applied that adversely impact the
economic value of an enterprise. AML/CTF rules can get violated leading to major legal
complications for the company. It may even result in outright ban by AUSTRAC and as per
laws of New Zealand related to AML/CF. along with this, there can be imprisonment or fine
or both.

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Risk monitoring and review
Activities By whom By when
Conduction of safety audit Senior
managers
1st September,
2019
Identification of risks Team leaders 7th September,
2019
Categorising the risk
information
Senior
managers
10th September,
2019
Risk treatment plan
formation
Senior
managers
17th September,
2019
Approval from designated
authority
CEO, COO and
CFO
20th September,
2019
Risk removal plan
implementation
Workers 27th September,
2019
Risk monitoring Monitoring
officer
1st October, 2019
Mid-term review Senior
managers
3rd October, 2019
The role played by industry typologies
In the AML/CFT context, the term “typologies” refers to the various techniques used to
launder money or finance terrorism.

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New Payment technologies: use of emerging payment technologies for money laundering
and terrorist financing. Examples include cell phone-based remittance and payment systems.
Here BSl will be using of using New Payment Technology as Frontline financing is an
Online leasing company.
Trade-based money laundering and terrorist financing usually involves invoice
manipulation and uses trade finance routes and commodities to avoid financial transparency
laws and regulations. This is also one of the threats from Frontline Financing as it is solely
dependent on online platform.
Identity fraud / false identification: used to obscure identification of those involved in
many methods of money laundering and terrorist financing. The risk rate is very high as the
KYC and CDD is done through online platform.
Role of BSL’s risk appetite
The amount of risk an entity is willing to accept or retain in order to achieve its objectives. It
is a statement or series of statements that describes the entity’s attitude towards risk taking.
Determining an entity’s risk appetite occurs through the development of risk appetite
statements which clearly set out what the executive consider to be acceptable risk-taking.
Risk appetite statements are usually aligned to categories of risk e.g. financial, people and
reputation risks.
In every merger and acquisitions, there are certain risks which the premier institutions must
take. BSL is an Australian company, never exposed to the outside environment (Ha, 2019).
Along with this, BSL has never handled the business of such type in Australia (Harbitz et al.,
2016). After the acquisition, there will be a complete overhaul of administration in BSL so
there is a need to consider the risk appetite of BSL without which no decision can be taken
(Hartung, 2017).
How to review the ML/TF assessment?
There would be mid-term review of ML/TF assessment to cater to new needs of the
organization. There is need of timely review of assessment method (Hsu et al., 2017) so the
ML/TF assessment will be reviewed after every 3 year along with mid-term reviews

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depending on need of the hour. Top review the likelihood, impact and score related to
potential of risk will be assessed using above mentioned tools identified in previous section
(Jedrzychowska & Poprawska, 2016). Along with this the risk assessment will be done
considering standards mandated by AUSTRAC and financial intelligence agencies of New
Zealand (Laryea et al., 2018). This will make the process comprehensive enough to fulfill all
needs associated with risk methodology (Lema et al., 2016).
ML/TF vulnerabilities
1. Vulnerabilities arising due to online trade financing and leasing products
Due to the online method of transactions, BSL can get mired into controversies related to the
funding of banned organizations over the world like Taliban, Jaish-e-Mohammed, ISIS, etc.
Along with this cryptocurrency and blockchain technology is not legal in some countries. the
online nature of transactions may lead to an exchange of Cryptocurrencies (Lever & Kifayat,
2016). Thus, the company may be accused of illegal financing. Along with this many shell
firms trade and lease online so BSL can be a victim of the issue of black money (Locke et al.,
2017).
2. vulnerabilities arising due to running an offshore branch that provides products and
services to New Zealand customers
There can be monitoring problem due to the offshore nature of the entity leading to bad work
culture (Management, 2017). To be more concerned with, the illegal activities can be funded
by FF due to the lack of effective monitoring. Terrorism financing and many scandals can
happen due to lack of administrative accountability. There can be illegal funding for elections
occurring all over the world (Mansour & Jaaron, 2018). The bogus shell companies may get
registered on the online trading platform leading to the parking of black money.
Discussion of conclusions due to the impact of different strategies
There is a need to do situational analysis before arriving at any decision related to the
acquisition. If BSL decides to acquire the FF, it will have to set up a robust monitoring

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system because of offshore trading of money (Masterov et al., 2016) (McBride, 2017). The
company will have to abide all the rules and regulations laid by Reserve bank of New
Zealand and Financial Market Authority (FMA) to enter to its new market.
Part 2
Introduction
The assessment 1 carried in previous paper considered a company named BSL. BSL was
considering acquiring new business in New Zealand named FF. In assessment one, the
research methodology for risk assessment was identified and presented. In this part of the
project, it is assumed that the company has decided to acquire the online trading business of
FF. so there is a need to place controls which are identified and implemented in this part of
the project (Fitzpatrick et al., 2017). BSL is an Australian company trying to expand in other
markets. It is in the process of acquiring new business, but that new business has certain risks
which have been identified in assessment one. This assessment caters to the need of
placement of controls to avert the risks identified in the previous paper.
AML/CTF controls
Initial controls required
1. Controls on number of transactions done by a single company or individual
2. Controls on the amount of money traded on the platform along with a restriction on an
extra amount of leasing
3. Controls on type of countries to be provided facility especially safe havens for money
laundering and terrorism financing
4. Controls on any unauthorized transaction

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Controls required on an ongoing basis
The controls required on an ongoing basis are a restriction to countries acting as safe havens
for money laundering and terrorism financing (Essabbar et al., 2016). The suspected
individuals or companies should be barred from trading and acquiring services of BSL. There
must be control on suspected or wrongfully earned amount.
Current controls to be used
Currently, BSL provides services to its customer only after proper authentication of identity
documents and recognizing the source of money. These controls will be used after acquiring
the FF also. Along with this BSL has control on recordkeeping whereby every transaction is
recorded in an electronic system. The limited number of individuals can access these records
so there are very fewer chances of tempering (Farughi et al., 2016). There have been controls
over the number of persons entering the premises of the office. This control will also be kept
the same after the acquisition.
Stakeholders to be consulted
All financiers of the company will be consulted for approval of plans related to controls.
They will be persuaded to provide money for placing the necessary internal and external
controls in the company (Elboshy et al., 2019). Other stakeholders will be executive. Before
implementing any plan, there will need to take concerned executive authorities in confidence
so that change is implemented. Employees will also be taken into confidence as there can be
older employees who may be reluctant to place new controls or make earlier controls get
regulated strictly. There will need to consult experts on the matter so that the plan is
adequately formed and implemented.
Status of current controls
There will need to modify current controls according to new needs with the acquisition of a
new company (Ritter et al., 2017). Some current controls like identification of person
availing the financial service of BSL, restriction on the amount to be raised, etc. will work
adequately as such but the one related to online trading and leasing must be modified to cater

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to new needs with new responsibilities due to the acquisition of new organization (Phadtare
et al., 2018). Along with this, certain new controls need to be established for example
recognizing the channels of financial trading online, recognition of the origin of trading,
regular identification of bogus companies, etc.
Required new controls
There is a need for new controls with the changing nature of work of the company. The
priority among new control is to identify the individual or entity involved in online trading.
This will result in the recognition of bogus companies leading to the prevention of money
laundering. Along with this, there must be other controls (Ryabinin, 2015). As mentioned
above the channels of routing of money in the company must be recognized so that no illegal
trading and leasing take place while executing the work related to day to day business of the
company. There must be adequate control of recognition of the origin of the money so that
the money traded on the online platform may be recognized as legal or illegal. There is a
need for effective monitoring for which digital means of communication will help the most.
There must be a digital transformation of the company so that the company can monitor each
relevant activity from the office of Australia. The customers need to be identified so that no
criminal or terrorist can access the platform. There must be a prudent information system to
regulate the activities as per standards of AUSTRAC.
B) Assumption of approved control
It is assumed that the priority control of identification of person or entity trading online has
been approved. There is a need to identify each individual and entity which is associated with
trading and leasing activities of the company. This will make BSL effectively monitored
company with sound fiscal management (Ryabinin & Strukov, 2018). There must be
effective communication channels to deal with the issue of distance-based business or
offshore location of headquarters of FF. this will make the company recognize each
individual associated and it will be able to eliminate the chances of money laundering and
terrorism financing through its platform.

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How to design the approved control?
The approved control must be designed appropriately so that the risk associated with online
money trading can be removed. There will be setting up of a desk authority which will cater
to the need of identification of persons using the services of the company. The online
registration system would be set up which will provide different long in ID for each person or
entity availing the services of the company. The concerned person will have to submit the
relevant documents like address proof, citizenship, source of money, etc. these documents
will be scanned by the desk authority (Scannella, 2016) Only after complete recognition of
the individual, the login ID will be provided. Thus, every person who avails the services of
the company will have to identify himself or herself. For authenticating the documents, the
experts would be hired who will identify the persons associated with transactions happening
online (Sandal, 2018).
Working with stakeholders
The plan will be formulated by the chief manager with the consultation of all stakeholders.
The desk authority will be set up with the help of all stakeholders associated with the day to
day working in the company. The plan will be approved by financiers to set up a desk
authority and pay him or her monthly with adequate provisions to hire talented persons as
experts (Selim et al., 2019). There will be approval from executive so that plan gets
authorized from the company and there is set up of desk authority catering to the need of
identification of each individual. The local level employees will be consulted and given a
presentation of the plan so that change is implemented without any hiccup. Not taking
employees into confidence may result in resentment among employees that may culminate
into the severe situation like strike or loss of key employees. The plan will be presented to
government authorities in the form mandated by AUSTRAC so that all legal requirements
are complied with. This will prevent future legal complications which cost a huge amount of
profit once litigation is filed against any company (Singh & Siwach, 2018). To prevent that
happening in the future, all legal requirements related to AML/CTF activities will be met
(Shafiee, 2016).

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Allocation of responsibility
The senior manager of the concerned regional branch in New Zealand will be allocated
responsibility to formulate a plan for the mentioned control and implement the changes as
required. The senior manager will be able to persuade higher authorities as well as local
employees. The concerned branch manager must have intellectual knowledge related to
business to be conducted in a foreign country (New Zealand). This will lead to the
implementation of change without any major problem (Singh & Sur, 2018). The
contingencies will be planned according to the situation so that they are sorted out at the right
time by the right person.
Monitoring the control
Money Laundering Reporting Officer (MLRO) will be appointed to cater to the need of
monitoring an offshore entity. MLRO will comply with the requirements related to regular
update about money laundering activities to government authorities and board of BSL. There
will be need of accessing the transaction files and other relevant material so MLRO will be
provide adequate authority to conduct his work without any fear, favor or ill-will. The senior
person with impeccable character and integrity will be appointed for the purpose of
monitoring work in FF in NewZealand. This will make the organization flexible enough to
cater to the need of monitoring an offshore entity without any hassle.
c) System designing for regular update
Senior manager of each regional branch will be given the responsibility to monitor the
changes. He will be asked to authorize the desk authority to maintain a record of persons
identified (Solozhentsev, 2018). Each person who comes online for trading and leasing will
be identified so bogus companies and individuals will be identified in the system. Their
information will get registered into the electronic system of the company. So if that person
tries to register again, he or she will be recognized by the system leading to the withdrawal of
his application to avail the services of BSL. The branch senior manager will be asked to

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regularly monitor this record registration so that they remain up to date with services and
products of the company (Solozhentsev, 2015).
There will be the maintenance of record for number and amount of transactions carried
online through digital transformation (Soeteman-Hernández et al., 2018). This information
will get automatically update into the system of higher authorities sitting in Australia. Thus,
there will be regular monitoring by the means of a digital system and latest technologies
present in the world. The controls will be implemented through various technological
systems currently available in the world.
The digital transformation of the company will help deal with the issue of a regular update as
there will be regular addition of information with each latest development. This will maintain
transparency in the working of an organization that will lead to an increase in confidence
among employees (Strukov, 2015). It will improve the organizational branding and brand
positioning in the new market of New Zealand.
Conclusion
Thus, some controls currently present in the company will be able to place and monitor
controls with some modification. But, there is a need to place new controls as well so that the
diversification of business can be addressed. There is a need for effective monitoring by the
means of digital transformation that will address the issue of the offshore nature of the
company (Tembhurkar & Deshpande, 2018). There is a need for a regular update to be given
to higher authorities which is possible through digital transformation.

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Part 3
Introduction
As the compliance officer, the plan of AML/CTF is given here for the firm named Cash4U
Direct. The firm deals with remittances sent by persons working in Australia to three
countries- Fiji Islands, Nauru, and Papua New Guinea (Theodore et al., 2018). It was
established in Melbourne about 3 years ago and now has 5 branches (all in Melbourne).
There are certain lacunae from the perspective of compliance with AML/CTF standards in
the organization, but some are complied with. This paper presents a report for senior
management and owners updating all relevant details (Therrien et al., 2016)
A) Deficiencies in Cash4U in priority order
1. The company has not updated its risk assessment program which was due to be revised
after 3 years
2. There is no coherent strategy to categorize the countries as low or medium risk
3. It does not have a list of Politically Exposed Persons (PEPs) and randomly ask the
persons if they are politically exposed.
4. The customer continues to remit to 6 receivers
B) Report for owners and senior management
Key ML/TF risks and vulnerabilities facing cash4U are many. The risk assessment program
has not been updated which is mandated by the AUSTRAC. Long with this, there has been
no list of Politically exposed persons and no coherent strategy to remit the money to
receivers with one person remitting money to 6 receivers (Todinov, 2019). Moreover, the
records are checked after one month, not daily. In such a scenario the act of money
laundering and terrorist financing will not be stopped immediately as there is no checkup for
one month (Turnbull & Haddud, 2018).

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Plan to remove the deficiency
Deficiency Cost (in $) Time Resources
List of PEP 1000 1 week Legal expert
Risk assessment
program update
1000 1 week Senior managers
Better management
of customers
5000 1 month Physical and Human
resources
Strategy to categorize
the countries
1000 1 week Senior managers
Installation of system
of daily update
5000 1 month Technician and
technical managers
C) Interview with AML/CTF manager
The interview will be conducted to identify the stakeholders and present ideas related to
deficiencies in the controls.
Engagement with the stakeholders
The stakeholders to be worked with are senior management and top executive. There is a
need to persuade them to implement change in the organization to comply with all legal
requirements related to AML/CTF. Along with this, financiers are to be persuaded to provide
finance for the change implementation plan so that change can be done without financial
difficulties. The appropriate stakeholders will be identified based on the criteria of the benefit
accruing from services from the company (Diez & Palmero, 2018).
Stakeholders will be given a presentation regarding controls so that their knowledge related
to the deficiency of controls can be assessed (Turnbull & Haddud, 2018). To engage the
stakeholders the seminar would be arranged so that there can be two-way interaction with
inclusive participation of all stakeholders. The ongoing processes for effective controls will
be monitored through regular update regarding the transactions of remittances. Instead of a

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month, there should be a daily update to remove the deficiencies in the control system. there
must be a logical flow of information among all stakeholders so that a coherent strategy
regarding the process of controls can be formulated (Uzhga-Rebrov & Karaseva, 2018).
D) Own view justification
The strategy formulated in the seminar presentation will be effective to deal with most of the
problems associated with the organization from the perspective of AML/CTF standards
(Westphal et al., 2017). Thus, there is a need to consider the issue again with stakeholders so
that all issues are sorted out in one go (Bakumenko & Sigal, 2018). This will prevent the
legal complications related to requirements mandated by AUSTRAC. Already the
organization is facing a ban or sanctions imposed under concerned Australian laws (Verdelho
et al., 2016)
Stakeholder engagement plan
Deficiency The stakeholder engaged Means of communication
Completion of risk
assessment program
Senior management Direct face to face meetings
Listing of PEP persons Government authorities and
compliance officer
Relaying of message from
company to government
through compliance officer
Daily update of information
regarding transactions
Regional branch managers Seminar presentation
Better customer management Local employees Emails
Categorization of countries
based on sound and
unarbitrary grounds
Compliance officer Seminar presentation

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Key control
One key control of the cash4U organization is the formulation of a risk assessment program.
The company has not updated its program for the last 3 years. this will place the company in
a major disadvantageous position, if not acted swiftly. The risk assessment program is
mandated to be provided to AUSTRAC under Australian. To implement a plan to monitor
the effectiveness of new risk program, a high-level meeting will be arranged with key
stakeholders who will be intimated about the seriousness of the issue (Wise et al., 2018).
There will be a presentation on the consequences of not complying with the mandated
criteria. This will be an eye-opener for higher authorities who have not bothered to update the
risk assessment program before completion of three years. There need to assess the impact of
this indifferent attitude (Zanko & Dawson, 2012)
Conclusion
It can be concluded from the above findings that Cash4U Direct organization has major flaws
in its compliance with AML/CTF laws or standards. There is a need to provide a risk
assessment program to AUSTRAC immediately so that further sanctions are not imposed on
the company as far as AML/CTF activities is concerned. There are high chances of money
laundering and terrorism financing activities on Cash4uDirect platform so there is need to
comply with all regulations of AUSTRAC and any other agency related to these activities in
New Zealand.

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