Some firms had not read previous thematic review reports and it was concerning that some prescribed businesses exhibited poor practices that had been previously identified and pointed out in the reports.
Determining whether an engagement is a business relationship or occasional transaction is important for applying appropriate controls;
Insufficient oversight of outsourced functions;
Insufficient details on source of funds and wealth verification;
Different engagements have different risk levels and require different levels of due diligence and ongoing monitoring;
Risk assessments did not always consider all risks and customer identification;
The review identified deficiencies in policies, procedures and controls;