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2.0 - AML/CTF program: Part A (general)
The AML/CTF Act adopts a risk-based approach to AML/CTF. This gives reporting entities the flexibility to address and deal with money laundering and terrorism financing (ML/TF) risks they may reasonably face in ways that are relevant to the nature, size, complexity and resources available to their business. These factors will determine how Part A components are applicable to a business and the level of detail that should be documented in the AML/CTF program.
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2.1 Adding ML/TF risk management to existing risk management strategies
2.2 Oversight by boards and senior management
2.3 Risk awareness training programs for staff
2.4 Employee due diligence
2.5 Appointing an AML/CTF Compliance Officer
2.6 Independent review
2.7 AUSTRAC feedback
2.8 Permanent overseas establishments
2.9 Risk indicators for an inadequate Part A
2.10 Part A for designated business groups
Summary
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