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Actually implementing the AML/CTF program is a process that may be divided into several stages, for example:
- specifying the AML/CTF program implementation
- planning the AML/CTF program implementation
- communicating the AML/CTF program implementation plan to your organisation
- agree on and delegate AML/CTF program implementation actions.
1. Specify the AML/CTF program implementation
The project manager for the AML/CTF program implementation project may consult with stakeholders about how the AML/CTF program will be implemented. The proposed AML/CTF program should be checked against legislative and business requirements to identify and address any deficiencies. The template of the implementation plan may include:
- a description of its purpose, aims and deliverables
- a statement of parameters such as timescales, budgets, range, scope, and authority
- a statement of people and/or roles involved and the way the team/s will work to implement the program, including specifying such things as frequency of meetings, functional responsibilities, decision-making processes, etc.
- a list of 'milestones' to set progress standards, review progress and schedule regular activities and reviews
- a statement of progress and results which will be measured and evaluated.
Important |
The first AML/CTF compliance report was due on 31 March 2008.
From 12 December 2008 all reporting entities will be required to:
- report certain international funds transfer instructions (IFTIs) of any amount within 10 business days
- report threshold transactions over $10,000, within 10 business days
- lodge suspicious matter reports (SMRs) to AUSTRAC, within 3 business days (or 24 hours if related to terrorism financing)
- carry out ongoing customer due diligence.
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