We have observed inconsistencies between individual enforcement officers’ supervisory reports, particularly from DIA’s AML Group.
In December 2019, we submitted an OIA request to DIA. This asked DIA to clarify how they instruct their AML Group to conduct on-site and desk-based reviews of reporting entities’ AML/CFT risk assessments and programmes.
Our requests are included in the OIA response, attached below.
This response raises a number of questions. We will seek clarification from DIA. Watch this space.