Planning establishes the objectives and processes necessary to deliver results in accordance with the specifications of the plan. In this case the specifications will include meeting obligations under the AML/CTF Act and to manage the identified ML/TF business risks.

Doing is the implementaion of the plan.

Checking is monitoring and evaluating the implementation and the processes and results against the objectives and specifications. It also involves reporting the outcome.

Acting is analysing the results of the checking stage, followed by designing remedies and improvements where the implementation is either not achieving the specifications of the original plan, or where the operating environment has changed. The acting stage then leads to planning for the next cycle of PDCA.

When carrying out the 'planning' and 'doing' steps, you may ask:

• What is the approach to the AML/CTF program?
• Does the approach support the overall goal?
• Is the approach a proven and tested approach?
• Has the approach been previously reviewed?
• What improvements, if any, were undertaken following the review?

When carrying out the 'checking' and 'acting' steps, you may ask:

• What has the performance of the AML/CTF program been?
• How does the performance compare against your original risk evaluations and analysis?
• Is your AML/CTF program working effectively?
• Are your AML/CTF program performance measures giving you an accurate picture of how well your business is meeting its regulatory obligations?