AMLA/SAAM Code of Ethics and Professional Conduct audit

The active members of the Association are reviewed within the scope of a periodic AMLA/SAAM Code of Ethics and Professional Conduct audit to ensure that they adhere to the Code of Ethics and Professional Conduct and the Anti-Money Laundering Act (AMLA). Towards this end they choose an auditor who meets the SAAM recognition requirements and thus provides a guarantee for flawless auditing activities.

The audit guidelines
The SRO Board of Directors annually determines in the Guidance on audit requirements how such audits are to be conducted, which auditing measures are to be carried out, who is able to conduct such audits for SAAM members, and finally, how the reporting is to be compiled. The members and auditors will be consistently kept up to date about the guidelines.

The audit report
After the audit has been conducted, the auditor compiles an audit report that is to be sent to the SRO Board of Directors, which informs them of the results of the audit. If the audit uncovers problems with adherence to the AMLA and the Code of Ethics and Professional Conduct, the SRO Board of Directors undertakes the necessary steps.

Measures to be taken in case of problems
A reminder or warning is issued in cases of minor infractions. Penalties are arranged if the infractions are more serious. Expulsion from the Association may follow in serious cases. The audit reports from the past year have revealed a positive picture. Only in several cases were warnings, penalties or expulsions from the Association necessary.

Important details for members and auditors

• Submission of the AMLA/Code of Ethics and Professional Conduct audit report: The audit report is to be submitted to SAAM by members within six months following closing of the business year. The report is to be sent to the regional office that is in charge of the member (Zurich, Geneva or Lugano). Sanctions will be levied for submissions that are late.
• Recognition of the auditors: The auditor is responsible for proving to the SAAM that the recognition requirements have been met.
• Risk classification obligation: Since January 1, 2007, active members must classify their business relationships and transactions on the basis of risk criteria.
• Auditors' seminars: To maintain the high level of know-how among the auditors, the SAAM organises auditors' seminars each year that specifically cover the Code of Ethics and Professional Conduct.