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anti-money laundering checklist
Customer Due Diligence
Verify the identity of the customer using reliable, independent source documents, data, or information.
Determine the customer's risk profile based on their background, transaction types, and business activities.
Conduct ongoing monitoring of customer transactions to ensure they are consistent with the institution's knowledge of the customer.
Maintain up-to-date information and records on the customer's identity and transactions.
Implement enhanced due diligence measures for high-risk customers, including politically exposed persons (PEPs).
Transaction Monitoring
Establish thresholds for identifying suspicious transactions that deviate from expected patterns.
Utilize automated systems to flag transactions that exceed predefined thresholds or match suspicious patterns.
Review flagged transactions promptly to determine if further investigation is warranted.
Document the rationale for decisions made about flagged transactions and the outcome of investigations.
Report suspicious transactions to the appropriate authorities as required by law.
Employee Training and Awareness
Provide regular training sessions on anti-money laundering laws and internal policies to all employees.
Ensure employees understand their role in detecting and preventing money laundering activities.
Distribute updates on new typologies, regulations, and trends related to money laundering.
Assess the effectiveness of training programs through tests or assessments.
Encourage a culture of compliance and make resources available for employees to report suspicious activities.
Record Keeping and Compliance
Maintain records of all transactions and customer interactions for at least five years.
Ensure records are easily accessible and can be provided to regulators upon request.
Conduct regular audits of compliance programs to identify and address areas for improvement.
Stay informed of changes in anti-money laundering regulations and update policies accordingly.
Designate a compliance officer responsible for overseeing the organization's anti-money laundering efforts.
