Revised Central Bank-AMLA Guidelines - Anti-Money Laundering ...

AML/CFT GUIDELINEISSUED BY THECENTRAL BANK OF BARBADOSIN CONJUNCTION WITH THE ANTI-MONEY LAUNDERING AUTHORITYMAY 2011i. Relevant money laundering and terrorism financing laws and regulations;ii. Definitions and examples of laundering and terrorist financing schemes;iii. How the institution can be used by launderers or terrorists;iv. The importance of adhering to customer due diligence policies, the processes for verifyingcustomer identification and the circumstances for implementing enhanced due diligenceprocedures;v. The procedures to follow for detection of unusual or suspicious activity across lines ofbusiness and across the financial group;vi. The completion of unusual and suspicious transaction reports;vii. Treatment of incomplete or declined transactions; andviii. The procedures to follow when working with law enforcement or the FIU on aninvestigation.12.0 PRE-EMPLOYMENT BACKGROUND SCREENINGThe ability to implement an effective AML/CFT programme depends in part on the quality andintegrity of staff. Therefore, licensees should undertake due diligence on prospective staffmembers. The licensee should ensure that senior management:i. Verify the applicant’s identity;ii. Develop a risk-focussed approach to determining when pre-employment backgroundscreening is considered appropriate or when the level of screening should be increased,based upon the position and responsibilities associated with a particular position. Thesensitivity of the position or the access level of an individual staff member may warrantadditional background screening, which should include verification of references,experience, education and professional qualifications.iii. Maintain an ongoing approach to screening for specific positions, as circumstanceschange, or for a comprehensive review of departmental staff over a period of time. Internalpolicies and procedures should be in place (e.g. codes for conduct, ethics, conflicts ofinterest) for assessing staff; andiv. Have a policy that addresses appropriate actions when pre-employment or subsequentdue diligence detects information contrary to what the applicant or employee provided.Anti-Money Laundering/Combating Terrorist Financing Guideline May 2011 31Bank Supervision DepartmentCENTRAL BANK OF BARBADOS