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Development of internal AML/CFT documents

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What internal AML/CFT documents are necessary to have?

It is essential to have several internal AML/CFT documents that regulate a company’s activities in preventing money laundering and terrorist financing. The main documents include:
  1. AML/CFT Policy: A document that defines the general AML/CFT principles and procedures, including customer identification and verification, risk assessment, transaction monitoring, and the procedure for reporting suspicious transactions.
  2. Risk Assessment Policy: An internal document describing the system for assessing risks related to customers and their operations. It establishes criteria for classifying clients by risk level and defines control measures for each category.
  3. Customer Identification and Verification Rules: Describes the process of collecting customer information, verifying their data, and assessing risks related to money laundering and terrorist financing.
  4. Procedure for Reporting Suspicious Transactions: Regulates the identification and reporting of suspicious financial transactions to the local FIU. It includes instructions on criteria for detecting such operations.
  5. Staff Training and Professional Development Program: A document that outlines the procedure for training employees on AML/CFT issues. It describes the frequency of training, the topics covered, and the qualifications required for employees.

AML/CFT Policy

AML/CFT Policy is an internal regulatory document of a company with AML/CFT obligations. It establishes procedures for client identification, verification, and due diligence, as well as the analysis of their financial activities and criteria for assessing the risks of financial transactions. The policy determines the procedure for identifying and reporting suspicious financial transactions, measures to prevent the legalization of criminal proceeds, and the financing of terrorism, ensuring the organization’s activities comply with legal requirements.​

Customer identification, verification and due diligence rules

Rules for Identification, Verification, and Due Diligence of Clients is an internal document for a company with AML/CFT obligations. It establishes procedures for collecting, verifying, and confirming information about clients to assess their compliance with legal requirements. These rules outline the process for client identification (obtaining basic identification data), verification (checking the authenticity of the information provided), and due diligence to assess the risks associated with a client’s financial activities.

Risk assessment policy

The risk assessment policy is an internal document for a company with AML/CFT duties. It defines approaches, criteria, and procedures for identifying, assessing, and managing risks related to money laundering and terrorist financing. The policy aims to identify and mitigate risks associated with these activities.

The procedure for reporting suspicious transactions

Procedure for Notification of Suspicious Transactions is an internal regulation that establishes the process for identifying, analyzing, and reporting financial transactions that may be related to the legalization of proceeds obtained through crime or terrorist financing. This procedure provides criteria for identifying suspicious transactions, mechanisms for documenting them, and the protocol for notifying the local FIU.

The AML/CFT Employee Training Program

The Employee Training and Professional Development Program is an internal document that defines the procedure for training and regularly developing employees in matters related to preventing the legalization of criminal proceeds and the financing of terrorism. The program includes educational events, training sessions, and briefings to familiarize employees with legal requirements, methods for identifying suspicious transactions, and proper risk assessment practices.

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