Navigating QFCRA’s AML/CFT Independent Review Guidance 2024 (v.3)

Are You Prepared for the New and Complex Requirements?

Introduction: A New Era of AML/CFT Compliance in Qatar

The Qatar Financial Centre Regulatory Authority (QFCRA) has raised the bar with its updated AML/CFT Independent Review Report Guidance 2024 (v.3). With new layers of complexity, firms are now required to dig deeper, document extensively, and test more rigorously to ensure compliance.

Key areas such as documented reviewer suitability, sanctions screening, and remediation tracking require significant effort and expertise. For many firms, this represents a considerable operational challenge—one that cannot be ignored.

If your firm wants to stay ahead of the curve and avoid penalties, now is the time to prepare. LAMAH Intelligent Solutions is here to help you navigate this process efficiently and effectively.

The New Scope: What’s Changed in Guidance v.3?

The updated AML/CFT Independent Review Guidance is not just about incremental changes; it expands the scope and introduces new mandatory processes. Here’s what firms need to tackle:

1. Documented Assessment of Reviewer Suitability

• What’s New: Firms must formally document the skills, experience, and independence of the reviewer. This is no longer optional—it’s a mandatory step.
• The Challenge:

• How do you prove reviewer competence in complex AML/CFT systems?
• How do you demonstrate independence without conflicts of interest?
• A poorly documented assessment could lead to report rejection.

• Our Solution: LAMAH provides for free a comprehensive Independent Reviewer Suitability Assessment Guide, ensuring your assessment is both rigorous and regulator ready.

2. Sanctions Screening and Targeted Financial Sanctions (TFS)

• What’s New: Firms must now demonstrate the adequacy and effectiveness of their sanctions screening processes. This includes testing for compliance with:

• • United Nations Security Council (UNSC) resolutions
  • National Counter Terrorism Committee (NCTC) notifications
  • Public Prosecutors Office (PPO) sanctions

• The Challenge:

• • Sanctions screening tools often produce false positives or miss critical matches.
  • Firms may lack proper documentation and testing to prove their systems work effectively.
  • High-risk jurisdictions and PEPs require additional scrutiny that many systems cannot handle.

• Our Solution:

• • LAMAH offers expert-led sanctions screening audits to ensure your systems are calibrated for accuracy and compliance.
  • We help you fine-tune your processes to reduce false positives without missing real risks.

3. Evidence of Remediation and Action Plan Tracking

• What’s New: Firms must test and report on the closure of past findings and include remediation efforts in the action plan. Key focus areas include:

• • Testing unresolved issues from the previous Independent Review Report.
  • Proving that actions were completed on time with appropriate documentation.
  • Highlighting delays, reasons, and senior management responses.

• The Challenge:

• • Many firms struggle with tracking and documenting their remediation progress.
  • Failure to close prior findings or demonstrate progress will raise red flags during the review.

• Our Solution:

• • LAMAH develops structured Action Plan Remediation Trackers to ensure findings are addressed effectively and documented to QFCRA standards.
  • Our team supports senior management with clear, prioritized remediation roadmaps.

4. Deeper Testing: Transactions, Customer Files, and Employee Screening

• What’s New: Firms must conduct more detailed and extensive testing across critical areas, including:

• • Transaction Monitoring: Testing a sample of transactions for money laundering and terrorist financing risks.
  • Customer File Reviews: Testing for compliance with KYC/CDD/EDD requirements.
  • Employee Screening: Ensuring higher-impact employees meet AML/CFT standards.

• The Challenge:

• • Do you have the resources to test transactions and files in a methodical, defensible manner?
  • How do you balance detailed testing with the need for timely completion of the report?

• Our Solution:

• • LAMAH’s AML specialists conduct targeted transaction and customer file testing to identify gaps quickly and efficiently.
  • We ensure all testing results are documented with clear observations and actionable recommendations.

Why Acting Now is Critical

The QFCRA has made it clear: non-compliance will result in penalties, rejected reports, and increased regulatory scrutiny. Firms must:

• Submit their Independent Review Reports by 31 July 2025.
• Ensure the review covers a minimum period of 12 months.

Without proper preparation, firms risk falling short of the new requirements.

Your Trusted Partner for AML/CFT Compliance

At LAMAH Intelligent Solutions, we understand the challenges firms face under QFCRA’s updated guidance. Our team of experts is ready to:

1. Conduct comprehensive Independent Reviews in line with Guidance v.3.
2. Assist with Reviewer Suitability Assessments to meet the new documentation requirements.
3. Test your sanctions screening systems, transaction monitoring, and customer files to ensure they comply with QFCRA standards.
4. Develop and track robust remediation plans to address findings effectively.

We combine deep technical expertise with practical solutions to help you stay compliant, reduce risks, and focus on your core business.

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Disclaimer:

The views and information expressed in this article are provided for general informational and educational purposes only and do not constitute professional, legal, financial, or investment advice. LAMAH Intelligent Solutions and the author(s) make no representations or warranties as to the accuracy, completeness, or suitability of the information contained herein and accept no liability for any loss or damage arising from reliance on it. Readers are advised to seek independent professional advice before making any decisions based on this content.