Compliance Programme

We recommend that your AML/CFT Compliance Programme be reviewed formally on an annual basis once you have established a mature compliance regime.

While AML/CFT is still new to your agency, it is recommended that you review your AML/CFT Compliance Programme more often i.e. every three months. This will ensure that as how approach practically undertaking your AML/CFT obligations evolves, your documents are updated to reflect your specific agency’s AML/CFT regime.

You will also need to update your AML/CFT Compliance Programme to reflect any changes to the Act, guidance from the DIA and any other relevant updates.

Your Compliance Programme includes further detail in the "Review and amendment of Compliance Programme" section of the document. We recommend you set tasks within the AMLHub to remind you to conduct these reviews.

Risk Assessment

We recommend that your AML/CFT Risk Assessment be reviewed formally on an annual basis once you have established a mature compliance regime.

While AML/CFT is still new to your agency, it is recommended that you review your AML/CFT Risk Assessment more often i.e. every three months. This will ensure that as you obtain more detailed data/information about your clients (jurisdictional risk etc.), your Risk Assessment will continue to be accurate and reflect your specific agency.
In the "Review of Risk Assessment" section of your Risk Assessment, further detail is included. We recommend you set tasks within the AMLHub to remind you to conduct these reviews.