What are the core elements of an AML/CFT Program that every regulated entity is required to have in place?

AML/CFT Programs are comprised of a detailed and complex set of requirements which must be carefully understood

The core elements every AML/CFT Program must have in-place includes:

• Registration with the AML Supervisor
• Establishment of designated business group
• Initial and ongoing ML/FT Risk Assessment
• Develop an AML/CFT Program & obtain Board signoff
• Appointment of an AML/CFT Compliance Officer
• Establishment of AML/CFT Risk Framework
• Ensure Board and Executive Mgmt. Oversight
• Establish a Customer Due Diligence Program
  • Collection of KYC information (i.e. app. forms)
  • Verification of KYC information (i.e. paper vs. E-IDV)
  • Beneficial ownership checks
  • PEP/Sanctions watchlist screening
  • Flag customers presenting higher ML/FT risks
  • Enhanced customer due diligence
  • Exception handling (i.e. discrepancies in KYC info.)
• Ongoing Customer Due Diligence
  • Re-screening higher risk customers
  • Transaction Monitoring and Reporting Program
• Initial and ongoing Employee Due Diligence
  • Defining key risk roles and tracking staff in these roles
  • Pre and post employment screening
• Initial and ongoing ML/FT risk awareness training
  • General AML/CFT training
  • Role-based AML/CFT training
• Record-keeping on all aspects of AML Program
• Managing third party reliance risks
• Reporting – suspicious matters, compliance etc.
• Independent audit of AML program effectiveness
• Managing feedback from AML supervisors
• Ongoing maintenance of AML/CFT Program to ensure compliance with rules, laws and typologies.