AML / CFT post-implementation check
Take 30 seconds to complete the questions below to see how well you have implemented AML / CFT into your business.
- Has your Operations Manual been updated to reflect your AML / CFT programme? Are the policies and procedures you have in your AML / CFT programme actually in place?
- Do you have a defendable methodology for conducting customer due diligence (CDD) for all new clients (and existing clients if required)? Refer to the AML / CFT manual for an explanation of CDD requirements.
- Have you and all staff undergone AML / CFT training to prove you have the knowledge, competency and skill to comply with the legislation and regulation? If you and/or your staff need training see our AML / CFT training options.
- Have your data collection documents, CRM, client file checklists, product application checklists and induction programme checklists been updated to reflect your AML / CFT obligations?
- Have you scheduled a time within the next three months to sit with staff and review your AML / CFT risk assessment and AML / CFT programme now that those are operational, and assess what might need to be changed or updated?
- Has the appropriate person in the business been registered with the Financial Intelligence Unit (FIU) so as to be able to use the goAML web tool to report suspicious transactions?
- Have you subscribed to the AML / CFT updates on the websites of FMA, DIA, FATF, FIU etc, to keep up-to-date any new methods of AML / CFT that may affect the business?
8. Have your professional development plan and CPD log been updated to reflect the AML / CFT training undertaken? Templates for these documents are available for download.
If you have implemented all the key actions listed above, it is likely you will currently be complying with your AML / CFT obligations.
If you cannot answer 'yes' to all the questions, then Strategi recommends you take the appropriate action immediately. If you are unsure about what to do or how to do it, contact us for assistance.