1. AML/CFT Program Management
Program Components Framework
Program Maintenance Schedule
- Daily: Transaction monitoring review
- Weekly: STR/CTR filing compliance check
- Monthly: Training progress assessment
- Quarterly: Risk assessment updates
- Annually: Full program review and Board reporting
2. Risk Assessment Methodology
Risk Scoring Matrix
Risk Mitigation Strategies
- Avoidance: Not serving certain customer types
- Transfer: Insurance for certain risks
- Mitigation: Controls and monitoring
- Acceptance: Conscious decision with Board approval
3. Regulatory Liaison and Reporting
FIU Communication Protocol
- Designated contact points for formal communication
- Response timelines for information requests
- Documentation of all regulatory interactions
- Escalation procedures for significant issues
Examination Preparedness
- Pre-Examination: Internal audit and gap analysis
- During Examination: Designated response team
- Post-Examination: Action plan for findings
- Continuous: Regulatory change monitoring
4. Staff Training and Certification
Training Needs Analysis
- Role-Based Requirements: Different content per department
- Skill Gap Identification: Assessment-driven content
- Regulatory Changes: Timely updates for new requirements
- Effectiveness Measurement: Testing and performance improvement
Certification Framework
- Level 1: Basic awareness (all staff)
- Level 2: Department-specific competency
- Level 3: Advanced compliance officer
- Level 4: Expert certification (Principal Officer)
5. Internal Audit and Continuous Improvement
Audit Program Components
- Scope Definition: Departments, processes, timeframes
- Testing Methodology: Sampling, interviews, observation
- Reporting Standards: Findings, recommendations, timelines
- Follow-Up Verification: Implementation confirmation
Continuous Improvement Cycle
Application to AML/CFT:
- Plan: Identify improvement opportunities
- Do: Implement changes
- Check: Measure effectiveness
- Act: Standardize successful changes
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