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

AML/CFT GUIDELINEISSUED BY THECENTRAL BANK OF BARBADOSIN CONJUNCTION WITH THE ANTI-MONEY LAUNDERING AUTHORITYMAY 2011a. The opening of customer accounts and verification of customer identity;b. Establishing business relations with third parties (including custodians, fundmanagers, correspondent banks, business introducers);c. Determining business relationships that the licensee will not accept;d. The timely detection of unusual and suspicious transactions, and reporting to theAuthority;e. Internal reporting; andf. Record retention.ii. The recruitment of a level of staff, appropriate to the nature and size of the business, tocarry out identification, and research of unusual transactions and reporting of suspiciousactivities;iii. An ongoing training programme designed to ensure adherence by employees to the legaland internal procedures, and familiarity with the dangers they and the business entity faceand on how their job responsibilities can encounter specified money laundering andterrorist financing risks;iv. Designation of a compliance officer at an appropriate level of authority, seniority andindependence to coordinate and monitor the compliance program, receive internal reportsand issue suspicious transaction reports to the Authority; See Sections 20 and 23 of theMLFTA.v. Establishment of management information/reporting systems to facilitate aggregate andgroup wide monitoring;vi. An effective independent risk-based oversight function to test and evaluate the complianceprogram; andvii. Screening procedures for hiring, and ongoing systems to promote high ethical andprofessional standards to prevent the licensee from being used for criminal activity.Policies should be periodically reviewed for consistency with the business model, and product andservice offering. Special attention should be paid to new and developing technologies.6.1 Risk-Based ApproachThe Bank recognises the diversity of the institutions it regulates and it will seek to establish that,overall, processes appropriate to institutions are in place and operating effectively. All licenseesshould therefore design an AML/CFT framework that satisfies the needs of their institution, takinginto account:i. The nature and scale of the business;ii. The complexity, volume and size of transactions;iii. The degree of risk associated with each area of operation;iv. Type of customer (e.g. whether ownership is highly complex, whether the customer is aPEP, whether the customer’s employment income supports account activity, whethercustomer is known to other members of the financial group);v. Type of product/service (e.g. whether private banking, one-off transaction, mortgage);Anti-Money Laundering/Combating Terrorist Financing Guideline May 2011 9Bank Supervision DepartmentCENTRAL BANK OF BARBADOS