An effective AML/CFT system is not a static construct — business models, risk profiles, and regulatory requirements are constantly evolving. Without regular assessments, blind spots emerge that subsequently become visible during audits. WCTS offers structured Health Checks that evaluate your AML/CFT organisation across all relevant dimensions in advance, whether to review efficiency or to prepare for an upcoming BaFin audit.
About
A health check provides a realistic picture of the maturity level of your AML/CFT organisation — going beyond formal self-assessments. The added value lies in the external perspective: weaknesses that are accepted internally as a given can be more clearly identified and prioritised from an objective, external point of view.
The assessment covers the following areas:
Governance and organisation — organisational and operational structure, roles and responsibilities, position of the Money Laundering Reporting Officer (MLRO), involvement of senior management, and interfaces with other control functions
Risk assessment and internal safeguards — timeliness and plausibility of the risk assessment under Section 5 of the German Money Laundering Act (GwG), consistency of the derived safeguards, as well as incorporation into policies and operating procedures
Operational processes — KYC, ongoing monitoring, suspicious activity reporting, and escalation pathways, including processing quality and documentation standards
System landscape — adequacy of the screening, monitoring, and case documentation systems used in relation to the risk profile
Training and awareness — content, frequency, and target-audience focus of training measures, as well as record-keeping
Upon request, we can align our methodology with BaFin's main audit areas and prepare the results in such a way that they can serve directly as a basis for internal measures or audit preparation.
