Governance and programs

Connect responsibilities, people and the AML/CTF program.

• How do the three AML governance roles differ?

  Separate oversight, approval and daily coordination so that each decision has an owner.

• What does a senior manager approve in the AML program?

  Tie approval to the actual risk assessment, policies and changed versions.

• What makes an AML compliance officer appointment workable?

  Check eligibility, authority, resources and continuity rather than only naming a person.

• Can one person perform all AML governance roles?

  Small size can change the role arrangement without removing the underlying work.

• How is an independent evaluation different from your own review?

  Use internal review to maintain the program and independent evaluation to examine it with suitable independence.

• How should you oversee an external compliance provider?

  Give external providers clear tasks, evidence requirements and an escalation route while retaining business oversight.

• When does an AML program become a working process?

  Connect the written program to staff actions, decisions and evidence.

• How to assess an AML service provider

  Check who will do the work, what they will deliver and how you will accept it before you engage an AML adviser or outsourced service.

• How to assess an AML software provider

  Test AML software against your own procedures, customer cases and record needs before you buy it.

• Why buying AML software is not enough

  Software can support AML work. Your business still needs an approved program, assigned responsibilities and evidence that its procedures are used.