Mastering Anti-Money Laundering and Counter-Terrorist Financing, 2nd Edition

3

The Role, Structure and Positioning of the AML/CFT Compliance Function

Structure and culture

AML/CFT best practice

Best practice in higher-risk products and services

IT systems

The use of artificial intelligence

Training, communication and awareness

A ‘pro-business’ approach

Management of internal suspicion reporting

STRUCTURE AND CULTURE

Core activities for the AML/CFT role

These can be summarised as follows:

• ■securing senior management support (a Board member should be responsible/held accountable for AML/CFT)
• ■the completion of an Enterprise Risk Assessment (ERA)
• ■producing, monitoring and updating policies and procedures
• ■providing an advisory support capability to the front line
• ■receiving, analysing and investigating internal disclosures ...