5.3 Program implementation tools (continued) |
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SWOT analysis

A SWOT analysis identifies the strengths, weaknesses, opportunities and threats existing in a business that will affect the implementation of the AML/CTF program. When weaknesses have been identified, you can attempt to counter these with the existing strengths that have been identified, or new strengths and capabilities will need to be developed in order to overcome these weaknesses. Similarly, when threats have been identified, these can be countered with the existing opportunities that have been identified, or alternatively new counters to these threats will need to be developed.
Strengths and weaknesses tend to be associated with factors and situations occuring within your organisation. Opportunities and threats tend to be associated with factors and situations arising outside your organisation.
Unique strengths such as existing resources, abilities, and processes that your business already uses may assist it to comply. For example, some areas of your business may already have risk management and compliance processes in place.
Deficiencies, lack of resources, or weaknesses in your business may need attention when implementing an AML/CTF program. For example, your staff may have no formal training in AML/CTF procedures, or your business may not currently keep computerised records.
Situations currently occurring in your business or its environment may provide opportunities that you could take advantage of to assist you to implement the AML/CTF program. For example, your business may currently be in the process of developing a new financial product for a new customer market that incorporates a number of designated services and will need to be AML/CTF compliant. This is an opportunity to integrate AML/CTF processes into the service provision of the product from its inception and to include specific AML/CTF topics into the staff training on the new product. New customers to the business who will be attracted to the product can be identified through the new customer due diligence processes from the introduction of the product.
New product types, new technologies, new markets and jurisdictions or criminal attempts to try new ML/TF methods may pose threats to an AML/CTF program. For example, conducting business in an overseas jurisdiction may offer the opportunity of growing your business, but if the jurisdiction's AML/CTF laws are not equivalent to Australia's, conducting business there may present a higher risk of ML/TF activities being attempted through the designated services your business offers.
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