AML-CFT Policies & Procedures
Well-written, concise, and continually updated AML/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.
The PMLFTR obliges every subject person to “have in place and implement the following measures, policies, controls, and procedures, proportionate to the nature and size of its business, which address the risks identified as a result of the findings emanating from internal customer and business risk assessment… and to apply a risk-based approach in relation to customer due diligence measures, record-keeping procedures, and reporting procedures...”.
The law establishes the said measures to including customer acceptance policies, customer risk assessment procedures, internal controls, compliance management, communications, employee screening policies and procedures, and 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 organisations in:
- drafting an AML/CFT Policy covering the applicable rules and regulations affecting the Company’s business, particularly from a risk perspective; and
- reviewing and updating the AML/CFT Policy to ensure all applicable AML/CFT rules and regulations are reflected in the Policy, particularly any additional regulatory items emanating from acquired licenses.
BDO Malta provides its customers with adequate policies and procedures that are commensurate to the money laundering and funding of terrorism (“ML/FT”) risks to which it is exposed. The drafting will ensure that any regulatory or sector-specific requirements are reflected within the written policies and procedures.
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