The specific preventive measures discussed above should take place within, and be supported by, a comprehensive institutional AML/CFT program that is appropriate to the risks the LFI faces. The core of an effective risk-based program is an appropriately experienced AML/CFT Compliance Officer who understands the LFI’s risks and obligations and who has the resources and autonomy necessary to ensure that the LFI’s program is effective. Additionally, the LFI’s senior management must clearly endorse and support the AML/CFT program.

As with all risks to which the LFI is exposed, the AML/CFT training program should ensure that employees are aware of the risks of cash-intensive business customers, familiar with the obligations of the LFI, and equipped to apply appropriate risk-based controls. Training should be tailored and customized to the LFI’s risk and the nature of its operations. For example, an LFI that has a large number of cash-intensive business customers should offer training that includes an in-depth discussion of risk factors and red flags related to such customers.