SUDAN: Bank of Khartoum Adopts Best Practices in AML/CFT to Combat Money Laundering and Financing of Terrorism

Strengthening Commitment to Combating Money Laundering and Financing of Terrorism

The Bank of Khartoum (BOK) has adopted best practices in Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) to strengthen its commitment to combating money laundering and financing of terrorism. The bank is fully compliant with Central Bank of Sudan’s regulations governing AML/CFT.

Components of BOK’s AML/CFT Program

The BOK’s AML/CFT program consists of eight key components:

• Policies and Procedures: Establishing a comprehensive set of policies and procedures to guide the bank’s AML/CFT operations.
• Risk Assessment: Identifying, assessing, and mitigating risks associated with customers, geographical distribution, products and services, and channels of delivering business.
• Customer Acceptance Policy: Requiring identifiable customers who meet specific criteria for minimum acceptance to establish a relationship with BOK and carry out business transactions.
• Know Your Customer (KYC) and Due Diligence: Verifying the identity of customers and their source of funds through due diligence processes.
• Transaction Monitoring: Screening all transactions against local and international sanctions lists and monitoring for unusual or potential suspicious activities.
• Suspicious Transaction Reports: Reporting all suspicious transactions to the Compliance Officer, who examines the reports and submits a formal disclosure report to the files.
• Staff Competency Education and Training Programs: Providing ongoing training and awareness programs for all employees at all levels to ensure they are aware of the bank’s policies and procedures regarding AML/CFT.
• Record Keeping: Maintaining accurate records of customer identifications, transactions documents, risk assessment documents, suspicious transactions reports, and training records for at least five years from the transaction date.

Compliance Structure

The BOK’s compliance structure is as follows:

• Board of Directors: Responsible for overall compliance with AML-related laws and regulations.
• Management: Ensures day-to-day compliance with anti-money laundering obligations within operational areas.
• Head of Compliance: Responsible for ensuring that BOK has a robust system for identifying and managing regulatory requirements.
• Internal Audit: Assesses compliance, adequacy of controls and systems, and adherence to policies and procedures.

Risk Assessment Approach

The bank’s risk assessment approach is based on:

• Customers
• Geographical Distribution
• Products and Services
• Channels of Delivering Business

The bank reviews its risk assessment framework twice a year to ensure that the existing controls are adequate and effective.