How to handle an ACPR inspection?
Dealing with an ACPR investigation over the anti-money laundering and countering the financing of terrorism (AML/CFT) system.
Assisting a regulated entity in the context of an inspection related to its AML/CFT program and in particular to the know-your-customer procedure, the detection of politically exposed persons and the implementation of appropriate due diligence measures
We help the clients dedicate appropriate resources to ensure the proper communication of the requested elements, providing convincing justifications on the robustness of the AML program and, where applicable, define the scope of the elements likely to be improved. Knowing how to best present the activity and the type of clients are all challenges for our clients when facing en ACPR inspection.
Our client's challenge
Knowing which resources should be dedicated and understanding what posture to adopt
The responsiveness and the preciseness of the responses provided are considered as critical while managing our relations with the ACPR during its inspection and collection of evidence. The objective of the company subject to the inspection, is to provide all the requested answers in a comprehensible manner highlighting the qualities of the system in place.
Our way
Responsiveness, balanced communication and appropriate remedies
We recommend appointing a dedicated contact person within the entity subject to the ACPR inspection, preparing the responses provided to the ACPR, in conjunction with the law firm in charge of representing the company’s interests.
The law firm ensures a precise and balanced communication with the regulator in order to understand its expectations and to clarify the actions taken by the company involved.
Finally, in case of actual breaches, sanctions can be mitigated through the demonstration of the implementation of remediation measures in a way to avoid the reiteration.