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Staff Crucial in Combating Money Laundering and Financing of Terrorism
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In a bid to effectively combat money laundering and financing of terrorism, financial institutions are required to have in place robust processes and personnel. According to the Anti-Money Laundering Act 2008 (Act 749) as amended, Accountable Institutions must assess ML/TF risks and ensure that their staff is equipped with the necessary skills and competencies.
The Role of the AML Reporting Officer
The AML Reporting Officer (AMLRO) plays a crucial role in this regard. This official, who reports to the Board of Directors, is responsible for:
- Developing an Anti-Money Laundering/Customer Due Diligence (AML/CDD) Compliance Programme
- Receiving and vetting suspicious transaction reports from staff
- Filing reports with the Financial Intelligence Centre (FIC)
- Ensuring that the institution’s compliance programme is implemented
Key Responsibilities of the AMLRO
The AMLRO also coordinates training of staff on AML/CFT awareness, detection methods, and reporting requirements. In addition, they serve as a liaison officer between the institution and the Bank of Ghana (BOG) and FIC, providing guidance on AML/CFT issues to employees.
Requirements for Effective Performance
To perform their duties effectively, AMLROs must possess relevant competence, authority, and independence. They should also be encouraged to acquire professional qualifications in anti-money laundering and financial crime.
Access to Information and Cooperation
Financial institutions are required to ensure that the AMLRO has access to all information necessary for consideration of suspicious or unusual transaction reports. Furthermore, they must declare their commitment to comply promptly with requests made by competent authorities and provide relevant information to BOG, FIC, and other relevant authorities.
Reporting Proceeds of Crime
In a related development, financial institutions are required to identify and report proceeds of crime derived from unlawful activities, including terrorism financing, human trafficking, drug trafficking, and others. This is in line with the Anti-Money Laundering Act 2008 (Act 749) as amended and the Anti-Terrorism Act 2008 (Act 762) as amended.
Conclusion
The staff of financial institutions play a vital role in combating money laundering and financing of terrorism. The AMLRO is a critical position that requires individuals with the necessary skills, competencies, and independence to perform their duties effectively. Financial institutions must ensure that their AMLROs have access to all necessary information and resources to enable them to carry out their responsibilities efficiently and effectively.
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