Al Majmoua Compliance Audit Advisory Services

Consultancy Objectives

The contracting authority seeks to engage a qualified consultant to conduct an independent "Readiness Audit" of the AML/CFT Compliance Unit’s operational capacity at Al Majmoua. 

The objective of the assignment is to: 

• Ensure the AML/CFT Policy is structurally sound and aligned with BDL/SIC "Minimum Standards." 

• Provide a gap analysis between policy on hand and implemented procedures.

• Provide a formal audit opinion to the Board Audit Committee on the Compliance Unit’s readiness for full regulation. 
• Provide post-audit transition support, including a simulated BdL pre-inspection and a sustainable compliance monitoring framework, to ensure the institution remains audit-ready throughout the transformation period.

Scope of work

The Consultant will evaluate the following five pillars using Internal Control Questionnaires (ICQs) and ERP Data Analysis: 

A. Policy Design & Inception Audit 

• Verify that the AML/CFT Policy aligns with BDL/SIC "Minimum Standards." 

• Verify that Al Majmoua has put in place the required departmental policies in compliance with BdL requirements.
• Assess the "Second Line of Defense" setup to ensure the Compliance Officer has the independence required for a regulated financial institution. 

B. Onboarding & Screening Validation 

• Audit a sample of digital client files for "Identity Stop Signs" (e.g., missing physical addresses, missing IDs, implementation of risk-based approach). 

• Sanctions Integrity: Re-verify a sample of client, staff and supplier names against the adopted sanction lists to ensure there are no breaches and that they are properly treated.

C.Transactional & ERP Testing (The "Technical" Audit) 

• For a sample of clients, verify that all KYC related documentation is properly stored on file and onto the system.
• The USD 1,000 Rule: Use Visual Dolphin (accounting system) and MajFin (Al Majmoua Management Information System) logs to identify all bulk payments >$1,000. Verify that the proper treatment of those cases based on approved policy. 

• Early Settlements: Filter for loans repaid within 3 months to ensure they triggered a "Red Flag" investigation. 
• Sanctions Integrity: Verify a sample of client names against the adopted sanction lists to ensure the system is catching matches and blocking them properly.
• Verify system vetting procedures according to BdL requirements.
• Audit the archiving rules for the different types of records and documents

D. Investigation & Training Quality 

• Process Audit: Review the Internal Suspicious Activity Reports (ISAR) and Investigation Logs (CIL) for completeness. 

• Staff Competency: Conduct spot-checks with field staff to verify they understand the AML/CFT policy. 

• Onboarding Rule: Audit HR records to ensure 100% of new hires were trained within one month of joining and that all staff are screened against sanction lists. 

E. Internal & IT Risk 

• Review IT access logs for "Access Alarms" (unusual login times) and "Data Spikes."