Developing robust policies, procedures and controls for Anti-Money Laundering (AML), Countering Terrorism Financing (CTF) and Countering Proliferation Financing (CPF) is crucial for your institution to mitigate the risks associated with financial crime. Finovate Research Consulting consultants can develop AML/CFT/CPF policies, procedures, and controls for your institution following the risk assessment. The framework will include the following;
This establishes a comprehensive policy statement that outlines your institution's commitment to compliance with AML, CFT and CPF laws and regulations. This policy articulates the institution's risk appetite, objectives, and the overarching principles guiding its AML/CFT/CPF efforts.
A risk-based approach will be used in your policy formulation which will emphasise the need to identify, assess and mitigate risks in line with regulatory requirements and industry best practices.
This defines your organisational structure, roles, and responsibilities for AML/CFT/CPF compliance, including the designation of a compliance officer and other relevant personnel. This will also specify reporting lines, escalation procedures, and oversight mechanisms.
This establishes procedures for conducting customer due diligence, including identification and verification of customers, ongoing monitoring of customer relationships and enhanced due diligence for high-risk customers.
This defines procedures for monitoring transactions for suspicious activity, investigating alerts and reporting suspicious transactions to the appropriate authorities in accordance with regulatory requirements.
This outlines requirements for ongoing training and awareness programs to ensure that your employees are equipped with the knowledge and skills necessary to fulfil their AML/CFT/CPF responsibilities effectively.
This specifies requirements for maintaining accurate and complete records of customer due diligence, transaction monitoring and suspicious activity reporting activities, in compliance with regulatory retention requirements.
This translates the policy into detailed procedures that provide step-by-step guidance on how to implement AML/CFT/CPF controls effectively. This will include;
● Document procedures for customer onboarding, risk assessment, transaction monitoring and reporting, ensuring consistency and clarity in execution.
● Defining escalation procedures for handling suspicious activity, including protocols for internal investigation, decision-making, and reporting to authorities.
● Establishing procedures for conducting periodic reviews and updates to the AML/CFT/CPF policy and procedures in response to changes in regulations, industry standards, or the institution's risk profile.
This involves implementing controls to operationalize your AML/CFT/CPF policy and procedures effectively throughout the organisation and will involve;
● Deploy technological solutions, such as transaction monitoring systems, customer screening tools, and data analytics, to enhance the efficiency and effectiveness of AML/CFT/CPF controls.
● Establish internal controls, checks, and reviews to ensure compliance with policies and procedures, including regular audits and independent testing of AML/CFT/CPF processes.
● Monitor key performance indicators (KPIs) and metrics to track the effectiveness of AML/CFT/CPF controls and identify areas for improvement.
Finovate Research Consulting can conduct regular testing and review of your AML/CFT/CPF policies, procedures, and controls to assess their effectiveness and identify weaknesses or gaps. We can also perform independent audits and reviews to validate compliance with regulatory requirements and assess the adequacy of AML/CFT/CPF controls.These findings from testing and reviews inform enhancements to your AML/CFT/CPF framework and address any deficiencies or areas for improvement.
By following this structured approach to policy, procedures, and controls development, your organisation can establish a robust framework for AML/CFT/CPF compliance that effectively mitigates the risks associated with financial crime while maintaining regulatory compliance and safeguarding the integrity of the financial system.