Fraud risk management and investigation services

Obliged institutions are responsible for implementation of efficient program ensuring compliance with applicable anti-money laundering and terrorism financing regulations.

KPMG Forensic and Dispute Services team offers comprehensive support in order to meet regulatory requirements related to anti-money laundering and terrorism financing, adjusting the proposed solutions to the needs of organisation and nature of the market.

Our team members are specialists with vast experience and expertise in the projects related to anti-money laundering and terrorism financing, providing services in the following areas:

Independent assessment of compliance with anti-money and terrorism financing regulations.

KPMG specialists offer support in detailed assessment of compliance of existing policies, procedures and related processes with domestic and international AML/CFT regulations, as well as with best market practices.

The assessment performed by KPMG team allows identification of gaps in comparison to regulatory requirements and best practises.  In response to observed discrepancies KPMG team presents our Clients detailed recommendations on how to perform their regulatory duties properly, in a manner tailored to Client’s demands.

Support in development and implementation of anti-money laundering and terrorism financing program (or its modification)

KPMG offers comprehensive support in development and implementation of effective anti-money laundering and terrorism financing program, minimising risk of noncompliance with dynamically changing regulatory requirements, particularly in the context of the European Union directives.

Support in process implementation

Our services include advisory in respect of duties arising from the AML/CFT regulations concerning transactions reporting, client identification, periodical reviews, cross check against sanction lists, etc. The scope of our services include:

• Technical support in process implementation through guidelines preparation (i.e. guidelines regarding scope of reported data and its format) which will constitute a basis for implementation/modification of IT systems
• Specialist support and advisory regarding necessary modifications in existing IT systems in order to fulfil regulatory guidelines
• Testing of modified IT systems designed to verify their operational correctness, concluded with recommendations for necessary changes. 

Support in performing Know Your Customer procedures according to requirements and instructions from the regulator

KPMG team has extensive experience in providing operational KYC support for domestic and foreign financial institutions. Our assistance may include:

• Support in the development and implementation of KYC mechanisms, including consulting services covering formation and modification of internal regulations and processes
• Operational KYC support, both in Basic Customer Due Diligence, as well as Enhanced Due Diligence, by means of secondment of experienced professionals
• Preparation and execution of dedicated training sessions for employees.

Broad AML related training offer

Our team offers a wide variety of trainings focused on anti-money laundering and financing of terrorism.

Training sessions prepared by our professionals bring to the forefront AML topics selected by the Client.

Our training offer includes basic training sessions introducing listeners to AML topics, as well as more advanced, specialized trainings pertaining to industry related AML issues.  

KPMG Forensic Technology team has extensive knowledge and years of experience in the identification, recovery, securing, and analyzing electronic evidence. Our team is part of an international network of KPMG experts, with which it maintains close cooperation. Selecting KPMG, our customers gain access to the latest technology and expertise used by our professionals in their daily work.

Forensic Technology supports the execution of various Forensic engagements by:

Acquisition of evidence in digital form

KPMG team uses professional software and equipment to secure evidence coming from both desktops, laptops and external hard drives, as well as data collected from mobile phones or smartphones. We are able to recover files and e-mail accidentally or intentionally deleted from the devices.

Data analysis

KPMG team has a number of specialized analytical tools used in the analysis of large volumes of data, including advanced tools for visualization of relevant data and specialized data mining software. Furthermore, using specialized tool and methodology to analyze the data, KPMG is able to provide assistance by identifying unusual behavior and transactions, which may indicate attempts to commit abuses, as well as identify weaknesses in the control environment that may indicate an increased risk of fraud in the future.

Review and management of the evidence

Reviewing thousands of documents from many different sources to find relevant information is very time-consuming. By using specialized e-discovery software, we are able to help you by organizing all documents in one complete, searchable database, which can be shared using the intuitive web interface and allows to find the most important documents using key words in a short time.

Poor anti-bribery controls might cause lowering ethical standards, loss of client’s trust and also run the risk of inspections and substantial financial penalties imposed by regulators.

Dynamic growth of domestic and international regulation network in the area of company’s internal controls increases the need for implementation and maintenance of effective anti-corruption mechanism.

On operational level organizations have to fulfill the obligation of performing analysis of bribery and corruption risk assessment, review of relationships with third parties (so called third party due diligence), introduce detailed procedures, ethical standards and code of conduct as well as communicate and enforce them effectively, including proper trainings for employees.

KPMG Forensic Team supports clients in achieving the highest anti-corruption standards by:

• Conducting a risk assessment, review and evaluation of the control environment
• Providing gap analysis and comparison of the current state of the controls with the best industry standards
• Review and assessment of cooperation with third parties
• Verification of existing anti-corruption policies and procedures
• Reviewing the risk of bribery relating to mergers and acquisitions
• Providing trainings to employees and third parties
• Support in specialized regulatory audits (FCPA and others). 

In the course of our engagements we collaborate with management helping to ensure that proposed solutions are conversant with the needs of the organization.

Specialized members of our team have years of experience in seeking and obtaining information, regarding individuals and businesses, using publicly available sources.

High standard of performance of KPMG Forensic and Dispute Services team provides thorough analysis and clear presentation of gathered data, including visualization of relationships between entities, benefiting from the use of advanced software and specialized analytical tools, such as KPMG developed K-3PID system.

Support in forensic investigations

Assistance in investigations in the form of corporate intelligence, including comprehensive review of publicly available data covering individuals and organizations in order to acquire information of strategic importance to ongoing investigation.

Integrity Due Diligence

Integrity Due Diligence (IDD) involves collection and analysis of information regarding the background, business track record, reputation and integrity of individuals and organizations, generally in relation to prospective or existing business relationships. IDD can identify risks unlikely to be revealed by financial and legal due diligence. It may include: Client Acceptance, Know Your Customer (KYC), Business Partner Due Diligence, Supplier/Vendor vetting.

K-3PID

K-3PID is an advanced technology-enabled tool supporting automated Due Diligence analysis by providing access to a wide range of global open data sources (including sanctions and regulatory lists, PEP lists, corporate and court registers as well as media and other internet sources). Our tool employs artificial intelligence enabled algorithms in the first stage of investigation in order to filter out false-positive results, saving both time and money.

K-3PID platform allows review of information in 25 languages, with additional built-in auto translate mechanism for 60 other languages. An additional benefit of K-3PID tool is its integrated Audit Trail functionality, allowing to document completed audit tasks. 

Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law imposes a number of new compliance obligations on businesses in the area of whistleblower protection. Organizations with more than 250 employees will be required to implement appropriate whistleblower reporting mechanisms. KPMG has the appropriate IT solutions for whistleblowing, as well as many years of experience and expertise in handling whistleblowing reports and conducting further work when potential irregularities are identified.

As a whistleblowing tool, we offer a web-based platform that enables both whistleblower reporting as well as the management and maintenance of reports by organizations. Reporting is done through an online form which enables users to include attachments. The tool offers:

• Anonymity of whistleblower reports,
• Data security and compliance with GDPR requirements,
• Module to enable anonymous communication with whistleblowers,
• Ease of configuration and implementation,
• Ability to generate statistics and reports to analyze submitted information and track trends quickly and easily.

Drawing on our experience in conducting fraud investigation projects and other investigative services, we offer support in the processing of reports received through the whistleblower platform. Our support may concern both the handling of the report and conducting further internal work of an investigative nature. The scope of our work may include, for example:

• Conducting interviews with the whistleblower or other designated individuals to obtain detailed information regarding the whistleblower report,
• Detailed analysis of documentation pertaining to the report, including data analysis procedures and review of accounting/financial/personal records,
• Forensic Technology procedures, such as securing devices (server/desktop/laptop/phone/other) that contain electronic data and reviewing their contents using a specialized tool,
• Conducting confrontational interviews with suspects to present facts and evidence obtained during the investigation,
• Identification of recommendations as to the next steps that need to be taken by the organization.