Elements of an AML/CFT ProgramThe five major elements of an AML/CFT Program are:
- The appointment of a person who is responsible for the implementation of the compliance program i.e. the Compliance Officer.
- The development and application of written compliance policies and procedures that are kept up-to-date, and include enhanced measures to mitigate high risks.
- A risk assessment of your business activities and relationships.
- The development and maintenance of a written ongoing compliance training program for employees, agents, and others authorized to act on your behalf.
- The institution and documentation of an effectiveness review of your compliance program (policies and procedures, risk assessment and training program) every two years (minimum) for the purpose of testing its overall effectiveness.
The Elements of an Effective AML-CFT Framework, UNODC, 2009.
On compliance: Four pillars of an effective BSA/AML program, James M. Deitch and Anthony Nguyen, 2016.
5 Key Components of an AML Compliance Program, Sum & Substance.