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8. Governance

يسري تنفيذه من تاريخ 13/7/2023

(AML-CFT Law Article 16.1(d); AML-CFT Decision Articles 4.2(a), 20, 21, 44.4)

In order for the AML/CFT framework of any organisation to be effective, it must be based on the foundation of a sound governance structure, and held together by a strong compliance culture.

The governance structure should take the following into consideration:

Establish clear accountability lines and responsibilities to ensure that there is appropriate and effective oversight of staff who engage in activities which may pose a greater AML/CFT risk.
Have the mechanism to inform the board of directors (or a committee of the board) and senior management of compliance initiatives, compliance deficiencies, STRs filed and corrective actions taken;
Develop and maintain a system of reporting that provides accurate and timely information on the status of the AML/CFT program, including statistics on key elements of the program, such as the number of transactions monitored, alerts generated, cases created and STRs filed;
Develop and implement quality assurance testing programs to assess the effectiveness of the AML/CFT program’s implementation and execution of its requirements.
 

FIs should also make sure to have management structures which are accountable for clear ML/FT risk management and mitigation measures, as well as appropriate independent control functions. Implicit in both the AML-CFT Law and the AML-CFT Decision are the elements of both, concerning which additional guidance is provided in the sections below.