Complying with Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Regulations: Key Points for Banks
Establishing a Strong First Line of Defense
- Clear policies and procedures: AML/CFT policies should be clearly specified in writing, communicated to all personnel, and contain instructions on how to maintain compliance with regulations.
- Effective communication: Ensure that all employees understand their roles and responsibilities in implementing AML/CFT policies and procedures.
Employee Screening and Training
- Screening prospective staff: Implement adequate policies and processes for screening prospective and existing staff to ensure high ethical and professional standards.
- Ongoing employee training: Provide ongoing employee training programs to adequately train staff to implement AML/CFT policies and procedures.
Chief Officer in Charge of AML/CFT
- Direct reporting line: The chief officer responsible for monitoring the fulfillment of all AML/CFT duties should have a direct reporting line to senior management or the board.
- Sufficient resources: Provide the chief AML/CFT officer with sufficient resources to execute all responsibilities effectively.
Risk Management and Internal Audit
- Internal audit role: Internal audit plays an important role in independently evaluating the risk management and controls, including conducting audits of the adequacy of the bank’s AML/CFT policies and procedures.
- External auditors’ role: External auditors should also have a role in evaluating banks’ internal controls and procedures in the course of their financial audits and confirming compliance with AML/CFT regulations and supervisory practice.
Transaction Monitoring System
- Adequate monitoring system: Banks should have a monitoring system in place that is adequate to address its risks, including automating the monitoring process if necessary.