Keeping records and regular evaluation of the AML/CTF program is essential. The AML/CTF program cannot remain static as risks change over time - for example, changes to your customer base, your products and service, your business practices and changes to the law.

Once documented, your business should develop a method to regularly check whether your AML/CTF program is working correctly and well. If not, you need to work out what needs to be improved and put changes in place. This will both help keep your program effective and also meet the requirements of the AML/CTF Act.