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AML/CTF Program

Reporting entities captured by the AML/CTF Act and Rules are required to have in place an AML/CTF Program. There are three types of Programs:

  • Standard AML/CTF Program (may be suitable for a stand-alone reporting entity)
  • Joint AML/CTF Program (may be suitable for multiple entities within a Designated Business Group structure)
  • Special AML/CTF Program (may be suitable where the only designated service a reporting entity provides is item 54 – a financial services licensee that arranges for another financial services licensee to provide products and services to its own customers)

Both a standard and a joint AML/CTF Program must contain Part A and Part B. Part A focuses on the identification, management and mitigation of ML/TF risks, while Part B deals with customer identification and verification processes.

Our Approach

We take the time to talk with our clients to obtain detailed information on your business and bear such information in mind when drafting the AML/CTF Program for you. This helps us tailor the Program to suit your operations, with a focus on practicality and flexibility. The entire AML/CTF compliance regime is ‘risk-based’ after all. We also take the time to go through the draft with you and answer any questions you might have before finalising the document.

Note that while Part A of the AML/CTF Program includes detailed discussions of the ML/TF risk assessment, the ML/TF Risk Assessment needs to translate these discussions into the actual ML/TF risk ratings of your customers. ML/TF risks can also be quite dynamic and as a reporting entity’s business grows and evolves, the Risk Assessment may need to be reviewed and adjusted more often than the Part A Program itself. For these reasons, we generally recommend that the detailed ML/TF Risk Assessment be separately documented outside the Part A Program.

To find out more about how we could potentially collaborate, simply click here to book an obligation-free virtual coffee with our founder and director Xiaoshu Liu.