M26115 – Building Defensible AML Files (Online)
Registration Time: 09:15
Sessions Time: 09:30- 11:30 including a 15-minute break
Speaker: Dr Elizabeth Sammut Borg
Venue: Online Webinar
Participation Fees
MIA Members: €28.00
Non-MIA Members: €50.00
Retired Members: €15.00
Students: €20.00
*Group bookings for 3 or more participants available.
Background Information
In AML/CFT compliance, completing the relevant checks is only part of the task. Firms must also be able to demonstrate what was considered, what evidence was obtained, how risk was assessed and why a particular decision was reached.
Building Defensible AML Files is a practical webinar examining the customer file through the lens of regulatory scrutiny. It considers how the applicable AML/CFT framework translates into the information, evidence, reasoning and audit trail that should be visible throughout the lifecycle of a customer relationship.
The session will move beyond simply identifying what documentation should be held. It will focus on what makes an AML file coherent and defensible, from customer acceptance and CDD through to risk assessment, source of wealth and source of funds, ongoing monitoring, internal escalation and, ultimately, termination and record retention. These are the principal stages around which the training material has been structured.
The webinar will combine regulatory requirements with practical examples and case-based discussion, helping participants consider whether their own files clearly evidence not only what was done, but why.
Specific Topics to be covered during the session
• AML regulatory framework and supervisory expectations
• Building and maintaining a defensible customer file
• Customer acceptance, CDD and beneficial ownership
• Customer risk assessment and documenting risk-based decisions
• Source of wealth and source of funds
• Ongoing monitoring, screening and customer reviews
• Suspicion, escalation and reporting decisions
• Customer exit, record keeping and retention
• Common file weaknesses and remediation
Why is the session of relevance to our members?
A compliant process is only as defensible as the evidence left behind. This practical webinar will help participants look at AML files from the perspective of the person who may eventually have to review, challenge or examine them. Rather than focusing only on whether required documentation has been collected, the session explores whether the file tells a coherent story: how the customer was assessed, what evidence supported key conclusions, why particular decisions were made, and how those decisions continued to be tested throughout the relationship. Participants will leave with practical insights they can apply when onboarding customers, conducting reviews, documenting source of wealth and funds, closing monitoring alerts, assessing risk or remediating existing files.
Target Audience
• MLROs and Compliance Officers
• AML/CFT and Financial Crime professionals
• CDD/KYC and onboarding teams
• Risk and Internal Audit professionals
• Other regulatory and compliance practitioners
Speaker’s Profile
Dr. Elizabeth Sammut Borg, a seasoned lawyer and compliance specialist, currently holds the
position of Money Laundering Reporting Officer (MLRO) and Compliance Officer for
Investment Firms, CSP and Retirement Pension Scheme companies. Previously, Elizabeth
headed the the compliance and legal division as Director of Legal and Compliance at Dixcart
Management Malta Limited, serving also as MLRO and Compliance Officer on companies
licenced to offer CSP and trustee services.
As a dedicated compliance specialist, Elizabeth focuses on navigating the intricate landscape
of anti-money laundering and counter-financing of terrorism regulations as well as specialising
in regulatory compliance for CSPs and trustees. Her extensive experience extends to serving
as MLRO for CSPs, Trustees, and Fiduciaries, as well as retirement pension schemes
companies. Beyond her role, Elizabeth provides AML training and guidance contributing to
the development and enhancement of compliance standards within the industry.
Dr Borg graduated as a lawyer in 2010, subsequently reading Master’s Degree in International
Criminal Law, with the United Nations Interregional Crime Institute in Turin. Before joining
Dixcart, Elizabeth served as an employment law prosecutor and also worked at the Court of
the European Union in Luxembourg, as a legal jurist in the research and documentation
department