Financial Crime World

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AML Unit Should Be Assigned to a Senior Staff Member Independent of Business Functions

A new report has revealed that the Anti-Money Laundering Compliance (AMLCO) unit should be assigned to a senior staff member independent of business functions at Bank of Cyprus.

Responsibilities of AMLCO Unit


According to the report, the AMLCO unit is responsible for providing information concerning common customers and activities for cases related to money laundering and terrorist financing. However, it has been recommended that the AMLCO unit be assigned to a senior staff member who is not involved in the bank’s business functions.

Recommendations


The recommendation comes as part of a broader effort to strengthen the bank’s anti-money laundering (AML) policies and procedures. The report notes that the bank’s current AMLCO unit is responsible for providing training to all relevant staff members on an annual basis, but that it should be assigned to a senior staff member who can provide more oversight and guidance.

Retention of Records


The report notes that Bank of Cyprus has a comprehensive retention period policy in place, which outlines the length of time that different types of records must be retained. The policy requires that all relevant staff members retain records for at least five years from the date of completion of a transaction or activity.

Training


The report highlights the importance of training for all relevant staff members on an annual basis. The bank’s AMLCO unit provides training to all relevant staff members, which includes familiarizing them with the procedures set out in the relevant manuals and enabling them to recognize and handle transactions and activities suspected to be related to money laundering or terrorist financing.

Group-Wide Information Sharing


The report notes that Bank of Cyprus has a group-wide information sharing policy in place, which allows for the exchange of information between different entities within the bank. This includes providing information concerning common customers and activities for cases related to money laundering and terrorist financing.

Complex Structures


The report recommends that Bank of Cyprus avoid setting up complex and potentially non-transparent structures. The bank should consider the results of a risk assessment performed to identify whether such structures could be used for a purpose connected with money laundering or other financial crimes.

Capital Adequacy and Liquidity


The report notes that Bank of Cyprus has a capital adequacy policy in place, which requires the bank to calculate its capital requirements emanating from money laundering and terrorist financing risks. The bank must also ensure that it has sufficient liquidity to meet its obligations.

Governance


The report highlights the importance of governance in ensuring the effective implementation of Bank of Cyprus’s AML policies and procedures. This includes the approval of the policy by the Audit Committee, the review of the policy by the Executive Committee, and the overall responsibility for drafting and enforcing the policy by the Compliance Division.

Conclusion


Overall, the report recommends that Bank of Cyprus strengthen its AML policies and procedures to ensure compliance with relevant regulations and to mitigate any resulting compliance risks. This includes assigning the AMLCO unit to a senior staff member independent of business functions, establishing clear procedures for implementing and monitoring AML policies and procedures, and ensuring adequate training for all relevant staff members.