Guidelines for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)

Introduction

Financial institutions play a crucial role in preventing money laundering and terrorist financing activities. The guidelines outlined below aim to help financial institutions implement effective anti-money laundering (AML) and combating the financing of terrorism (CFT) measures.

Key Points for AML/CFT Measures

Risk Assessment

• Financial institutions should assess the risk of money laundering or terrorist financing for each customer, country, geographic area, product, service, transaction, or delivery channel.
  • This assessment should be based on relevant factors such as:
    • Country risk
    • Customer risk
    • Product/service risk
    • Transaction risk

Customer Due Diligence (CDD)

• CDD measures should be applied to all customers to verify their identity and assess the risks associated with the business relationship.
  • This includes:
    • Verifying customer identification documents
    • Assessing the source of funds and wealth
    • Conducting background checks

Enhanced Customer Due Diligence Measures

• Higher-risk customers may require enhanced CDD measures, such as:
  • More frequent monitoring of transactions
  • Obtaining additional information about the customer’s background and purpose
  • Senior management approval for commencing or continuing the business relationship

Simplified Customer Due Diligence Measures

• Lower-risk customers may be subject to simplified CDD measures, which should still take into account the nature of the lower risk factors.
  • This includes:
    • Verifying customer identification documents
    • Conducting basic background checks

Thresholds for Attention and Due Diligence

• Financial transactions above a designated threshold (USD/EUR 15,000) require specific attention and due diligence measures.

Ongoing Due Diligence

• Financial institutions should regularly review existing records to ensure they remain up-to-date and relevant.
  • This includes:
    • Monitoring customer activity
    • Conducting regular audits