Sample Table of Contents (AML/CFT/PF) Compliance Program: AML Compliance Consultants

There are five crucial elements of an Anti-Money Laundering/Countering the Financing of Terrorism and Proliferation Financing AML/CFT/PF Compliance Program. These are ;

Risk Assessment;

Appointment of a Compliance Officer;

Internal Compliance Controls;

Training of employees and Senior Management;

Independent Audit.

Policy Statement

It must be explicitly stated that all employees must comply with the AML/CFT/PF policies and procedures. It may also be stated that the entity is committed to complying with the laws and regulations to combat money laundering, financing of terrorism and proliferation financing. 

An Overview of Money Laundering and Terrorist Financing

Define money laundering, terrorist financing and proliferation financing. Explain that there are certain reports that must be filed by certain businesses to file certain reports.

Internal Controls, Policies and Procedures

Detail the Customer Due Diligence and Know Your Customer Procedures.

 Explain the Enhanced Due Diligence Measures (EDD) to be applied to high risk customers.

State the procedures to govern all payment methods. What are the due diligence requirements for large transactions of TT$50,000 and over and wire transfers of $6000.

State whether there is an internal threshold in order for a Source of Funds Declaration (SOFD) to be completed.

Employee Training

It should be stated that the AML/CFT/PF training should be conducted at least one a year. The Compliance Officer and Alternate Compliance Officer need more intensive training.

Review of the Compliance Programme

The Compliance Program should be reviewed at least once a year. The Compliance Program must be updated to reflect amendments in the law.

Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

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