Our approach
1. Inventory and implementation plan
First, we start with a thorough inventory of the current set-up of your organisation. Based on this, we then prepare a concrete implementation plan.
In this phase, we determine:
- which improvement points should be prioritised
- which policy documents and procedures are required
- which roles and responsibilities must be documented
- which processes must be set up or adjusted
As a result, this creates a clear roadmap for implementation.
2. Drafting and refining policies
Next, we support the drafting or improvement of your organisation’s AML policy.
Depending on your organisation’s needs, this may include:
- risk policies
- customer due diligence procedures
- transaction monitoring procedures
- reporting procedures towards the Financial Intelligence Unit (FIU)
- governance and escalation processes
Furthermore, the policy is designed to be practical. As a result, it not only meets the requirements on paper but can also be used effectively in the organisation’s day-to-day operations.
3. Setting up processes and controls
However, policies alone are not enough. Clear processes and internal controls are also needed. Therefore, we help set up workable procedures for customer due diligence, risk assessments, monitoring, recordkeeping and internal reporting.
In doing so, we take into account the reality of the football sector. For example, we consider sponsorship relationships, transfers, investors, commercial partners and other money flows within the club. As a result, the procedures are both practical and aligned with the organisation’s day-to-day operations.
4. Embedding compliance within the organisation
In addition, a compliance framework only works if it is clear who is responsible for what. Therefore, we support the documentation of tasks, roles and responsibilities within your organisation.
Furthermore, we make sure the board, management and relevant employees know what is expected of them. As a result, they understand how to act in the event of increased risks or signs of unusual activity.
5. Ready for audits and supervision
Finally, the end result is an AML framework that demonstrably complies with the AMLR and is ready for internal controls, audits and regulatory supervision.
As a result, your organisation will have clear documentation, established processes and a practical basis for managing AML risks on an ongoing basis.
