Regulator’s Guide: Anti-Money Laundering (AML) Controls for Banking, Other Financial Services, and Non-Financial Sector

The Banking Commission is responsible for overseeing AML controls in the banking sector, but there is a lack of practical guidance provided to firms by public authorities regarding AML requirements beyond FATF recommendations and local legislation.

Overview of AML Requirements

• In 2010, an update of customer databases was required to retrospectively verify the identity of customers before the new AML regime was introduced.
• The country does not have a risk-based approach approved by the local regulator. Instead, there are strict guidelines in place for verifying customer identification information.

Customer Due Diligence

• There are no minimum transaction thresholds under which customer due diligence is not required.
• To verify customer identification information, banks must:
  • Verify the identity and address of the customer by reference to official identity papers.
  • For legal entities, verify legal documents and identify key individuals.
  • Conduct enhanced due diligence for high-risk customers.

Suspicious Transactions Reporting

• Banks are obligated to report suspicious transactions where the identity of the beneficiary or originator is unknown.
• There are no de-minimis thresholds below which transactions do not need to be reported.

AML Audits

• There is no legal requirement for a bank’s external auditor to report on the bank’s AML systems and controls.

Data Privacy

• The country does not have established data protection laws. However, there are prohibitions on the transfer of credit reports, criminal records, and medical data.
• Case law or other constitutional law may impact upon the transfer of information to this jurisdiction. However, there is no specific guidance provided by public authorities regarding AML requirements and data privacy.

Key Findings

• The country has a strict approach to verifying customer identification information.
• There are no minimum transaction thresholds below which transactions do not need to be reported.
• Banks are obligated to report suspicious transactions where the identity of the beneficiary or originator is unknown.
• There is no legal requirement for a bank’s external auditor to report on the bank’s AML systems and controls.
• The country does not have established data protection laws.

This article provides an overview of the AML controls in place for banking, other financial services, and non-financial sectors in [Country Name]. It highlights the key requirements and guidelines that banks must follow to comply with anti-money laundering regulations.