Standard Guidelines Anti-Money Laundering and Counter Financing ...

More documents

Recommendations

Info

STANDARD GUIDELINES ON AML/CFTUPW/GP1telephone number, fax number, e-mail address and suchinformation as may be required by Bank Negara Malaysia.10.3.3. The reporting institution should ensure that the roles andresponsibilities of the compliance officer are clearly defined anddocumented. The compliance officer should ensure the following:the reporting institution’s compliance with the AML/CFTrequirements;implementation of the AML/CFT policies;the appropriate AML/CFT procedures, including customeracceptance policy, customer due diligence, record-keeping,on-going monitoring, reporting of suspicious transactions andcombating the financing of terrorism are implementedeffectively;the AML/CFT mechanism is regularly assessed to ensurethat it is effective and sufficient to address any change inmoney laundering and financing of terrorism trends; the channel of communication from the respectiveemployees to the branch/subsidiary compliance officer andsubsequently to the compliance officer is secured and thatinformation is kept confidential;all employees are aware of the reporting institution’sAML/CFT measures, including policies, control mechanismand the channel of reporting;internal generated suspicious transaction reports by thebranch/subsidiary compliance officers are appropriatelyevaluated before submission to the Financial IntelligenceUnit in Bank Negara Malaysia; andthe identification of money laundering and financing ofterrorism risks associated with new products or services orarising from the reporting institution’s operational changes,including the introduction of new technology and processes.10.3.4. It is important and imperative that the compliance officer appointedby the reporting institution has the necessary knowledge, expertiseand required authority to effectively discharge his responsibilities,including knowledge on AML/CFT obligations required under therelevant laws and regulations, the latest developments in moneylaundering and financing of terrorism techniques, the AML/CFTmeasures undertaken by the industry and timely access tocustomer due diligence documentation and other relevantinformation.10.4. Staff Training and Awareness Programmes10.4.1. The reporting institution must conduct awareness and trainingprogrammes on AML/CFT practices and measures for itsemployees, in particular, ‘front-line’ staff and officers in-charge-of17
STANDARD GUIDELINES ON AML/CFTUPW/GP1processing and accepting new customers as well as staffresponsible to monitor transactions.10.4.2. The Senior Management must ensure that proper channel ofcommunication is in place to effectively communicate to all levelsof employees the AML/CFT policies and procedures. Theemployees should be made aware that they may be heldpersonally liable for any failure to observe the internal AML/CFTrequirements.10.4.3. In this regard, the reporting institution should make available itsAML/CFT measures for all employees and its documentedAML/CFT measures should at least contain the following:The relevant guidelines on AML/CFT issued by Bank NegaraMalaysia; andThe reporting institution’s internal AML/CFT policies andprocedures.10.4.4. The training conducted for employees should be appropriate totheir level of responsibilities in detecting money laundering andfinancing of terrorism activities and the risks of money launderingand financing of terrorism faced by the reporting institution. Thereporting institution should at least adapt its training needs to thefollowing levels of employees:New EmployeesProvide a general background on money laundering andfinancing of terrorism, the requirement and obligation tomonitor and report suspicious transactions to the complianceofficer and the importance of the “Know Your Customer”policy.“Front-Line” EmployeesEmployees who deal directly with the customers are the firstpoint of contact with potential money launderers andfinanciers of terrorism. Hence, they must be trained toconduct effective on-going customer due diligence, detectsuspicious transactions and the measures that need to betaken upon determining a transaction as suspicious. Trainingshould also be provided on factors that may give rise tosuspicion, such as dealing with non-regular customerstransacting in large cash, PEPs, higher risk customers andthe circumstances where enhanced customer due diligenceis required.Employees – Establishing Business RelationshipEmployees, who are responsible for acceptance of newcustomers, must receive the equivalent training given to“front-line” employees. The training should be focused on18
Page 2 and 3: STANDARD GUIDELINES ON AML/CFTUPW/G

Standard Guidelines Anti-Money Laundering and Counter Financing ...

Create successful ePaper yourself

Delete template?

Save as template?