How to develop an AML / CFT programme

Your AML / CFT programme MUST be based on your AML / CFT risk assessment. This means before you start developing your AML / CFT programme, you should have completed your risk assessment.

Your programme must take into account the risks your business can reasonably be expected to face from money laundering and financing of terrorism.

What is an AML / CFT programme?

An AML / CFT programme is a written record of the:

  • Policies (i.e. a set of expectations).
  • Procedures (day-to-day actions required to be undertaken to meet the expectations set).
  • Controls (tools to ensure the business meets the expectations set by undertaking the required procedures) you have in place to manage the risks you’ve identified in your risk assessment and comply with your AML / CFT obligations.

These policies, procedures, and controls must be adequate, effective, and sufficiently robust to reasonably address the risks identified in the risk assessment.

The programme must provide the policies, procedures and controls relating to:

  • Managing and mitigating the risks identified in the risk assessment.
  • Vetting of staff (if you have any).
  • Training of relevant staff (if you have any).
  • Applying appropriate customer due diligence (CDD).
  • Reporting suspicious activities.
  • Prescribed transaction reporting.
  • Ensuring adequate record keeping.
  • Keeping the AML / CFT programme up-to-date.
  • Preventing products and/or transactions that favour anonymity being used for money laundering and financing of terrorism.
  • Ensuring your business adheres to its AML / CFT programme.
  • Reviewing your AML / CFT programme and getting it audited.

How do I complete my AML / CFT programme?

Developing a robust and meaningful AML / CFT programme is not a simple five minute task. It is a legal requirement and hence needs to be done thoroughly, accurately and then documented. Your AML / CFT auditor will want to see the written programme and gain confidence that what is written is being implemented and that it is sufficient to meet the identified risks contained in the risk assessment document.

Strategi Institute has developed a training module and a comprehensive manual that will explain how to develop and document a robust AML / CFT programme. This manual includes guidance notes, checklists, appendices to explain what is risky and what is not, plus templates and example solutions. The manual will do more than just assist with your programme – it will provide you with a total solution to enable you to meet all aspects of your AML / CFT obligations.