As the importance of anti-money laundering has grown across the financial sector, obligations are being tightened not only for established financial companies but also for electronic financial business operators, virtual asset exchanges and others. Under the Act on Reporting and Use of Certain Financial Transaction Information and the anti-money laundering regulations, financial companies and others must undergo an independent audit at least once a year, conducted internally or by an outside expert.
Law Firm Changchun has advised domestic virtual asset exchanges and electronic financial business operators on independent anti-money laundering audits. Our anti-money laundering (AML) independent audit advisory work provides detailed services across five broad areas — (1) internal control frameworks, (2) enterprise-wide risk management frameworks, (3) customer due diligence, (4) transaction monitoring and suspicious transaction reporting, and (5) record retention and security management — grounded in domestic law, the guidelines of the Financial Action Task Force (FATF) and precedents in official interpretation. Drawing on extensive anti-money laundering experience, we analyze each company's current position, identify shortcomings and propose directions for improvement on that basis.