Well-written, concise, and continually updated Anti Money Laundering (AML) / Combatting Financial Terrorism (CFT) policies and procedures are the foundation of a sound AML/CFT framework within organisations conducting relevant activity or relevant financial business.
The Prevention of Money Laundering and Financing of Terrorism Regulations (PMLFTR) has been consolidated by the Regulator to provide guidance to subject persons on their obligations and duties to prevent criminals from disguising illegally obtained funds as legitimate income, and ensure proper controls are in place so as to disallow criminals from exploiting any vulnerabilities within internal organizational processes for their benefit.
It is in fact a legal requirement for every subject person to have in place and implement measures, policies, controls, and procedures, proportionate to the nature and size of its business, that sufficiently and clearly document the internal processes for customer acceptance, risk assessment, compliance management, communication, and employee screening.
For the proper enforcement of these internal controls, subject persons are to continually take appropriate and proportionate measures for the purpose of making employees aware of the measures, policies, controls, and procedures established by the organization; including the recording, maintenance, and update of the relevant policies on an ongoing basis to remain relevant and reflective of ongoing legislative updates.
BDO Malta can therefore assist subject persons in:
- establishing the required policies and procedures that are commensurate to the money laundering and funding of terrorism risks to which it is exposed; and
- ensuring that any regulatory or sector-specific requirements are reflected within the documented controls.