AML/CTF program stakeholders

Even though compliance with the AML/CTF Act is mandatory, a person with the responsibility to manage the implementation of an AML/CTF program may need to establish and organise the support of the business's key stakeholders to ensure a successful implementation. Note that the AML/CTF Act and AML/CTF Rules do not specify the role of a project manager; the term 'project manager' is used in this module in the general sense to refer to a person who is implementing an AML/CTF program.

When identifying who would be a stakeholder in the AML/CTF program, you should consider anyone you feel would be significant to the project. Consideration should be given to what each may require from the implementation project, who has influence or power over it and who has a role that contributes to a successful conclusion.