Governing bodies are accountable for AML/CTF program approval, oversight, AMLCO appointment, and risk assessment review.
Key concepts
What the board owns
Approve the program
Including the ML/TF risk assessment.
Appoint the AMLCO
Notify AUSTRAC within 14 days.
Receive AMLCO reports
At least every 12 months — more often if risk warrants.
Resource adequately
Headcount, systems, training budget.
Checklist
Board questions for management
- When was the ML/TF risk assessment last refreshed?
- How many SMRs did we file last year? Trend?
- How many independent-review findings are open?
- Are we ready for tranche-2 / regulatory change?
- How do our peers compare on AML/CTF metrics?