With the ever strengthening regulatory environment and rise in fine, penalties and prison terms, no one can deny the importance of a strong and well articulated AML & CFT Policy.
Further, the policy should be aligned with the business and operational structure of the Company.
The AML & CFT Policy aims to safeguard the Company against money laundering (ML) and the financing of terrorism. The Policy outlines the principles and minimum standards of internal AML/CFT controls which should be adhered to by the Company to mitigate reputational, regulatory, legal and financial loss risks
A strong AML & CFT policy is also required at the time obtaining license from the regulators in case of registration of a new company.
The document will cover the following essential requirements:
A. Local AML requirements
B. Governance
C. Compliance Committee Charter
D. Roles and Responsibilities
E. Risk Based Approach to KYC & CDD
F. AML & CFT Risk Assessment
G. AML Monitoring Tools & Controls
H. Sanctions Compliance
I. Outsourcing to 3rd Party
J. Training and Awareness
K. Know Your Employee
L. Reporting
M. Records Keeping