Financial Crime World

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.