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Anti-Money Laundering Compliance Checklist
Risk Assessment
Conduct a comprehensive risk assessment to identify potential money laundering risks associated with the firm’s clients, services, and geographic location.
Review and update the risk assessment regularly to reflect any changes in the firm’s business profile or external risk factors.
Ensure that the risk assessment is documented and approved by senior management.
Policies, Procedures, and Controls
Develop and implement internal policies, procedures, and controls designed to combat money laundering and comply with applicable laws and regulations.
Ensure that the policies and procedures address due diligence, ongoing monitoring, record keeping, and reporting of suspicious activities.
Regularly review and update compliance policies and procedures to ensure they are effective and in line with current laws and regulations.
Due Diligence
Perform client due diligence (CDD) before establishing a business relationship, including identifying and verifying the identity of clients.
Conduct enhanced due diligence (EDD) for higher-risk clients, including politically exposed persons (PEPs) and those from high-risk countries.
Establish and maintain procedures for ongoing monitoring of client transactions and activities to detect and report suspicious behavior.
Training and Awareness
Implement an ongoing training program for all relevant employees to ensure they are aware of money laundering risks, laws, and procedures.
Provide specialized training for employees in key positions, such as compliance officers, legal personnel, and those handling client transactions.
Maintain records of training sessions and employee attendance to demonstrate compliance with training requirements.
Reporting and Record Keeping
Maintain detailed records of all client identification information, due diligence checks, and transactions for a period as required by law.
Establish procedures to ensure timely reporting of suspicious activities to the appropriate authorities as mandated by applicable regulations.
Regularly review and verify that record-keeping and reporting mechanisms are functioning correctly and are accessible for audits and examinations.
Independent Audit and Review
Conduct regular independent audits of the anti-money laundering compliance program to assess its effectiveness.
Make necessary adjustments to the compliance program based on audit findings and recommendations.
Ensure that the audit process is conducted by qualified personnel who are independent of the compliance management functions.
