Implementation of AML/CFT Measures - Good and Poor Practices for Banks, FLCs & PSPs

Introduction

This paper sets out examples of good and poor AML/CFT implementation practices that may be used by the financial institutions (i.e. Banks, FLCs & PSPs) as a guidance on how to properly implement AML-CFT preventive measures. The examples of good and poor AML/CFT practices are derived from supervisory oversight activities, including on-site examinations, thematic reviews, risk and compliance meetings, etc. Our specialized AML- CFT teams conducted a large number of onsite examinations during which the following themes received priority over the past two years: business wide ML/TF risk assessment, client risk assessment and profiling, ongoing transaction and activities monitoring, enhanced due diligence measures, PEP clients, clients from high risk countries and transactions to/from high risk countries.