Reporting groups let entities share AML/CTF resources. A lead entity is responsible for shared obligations.
Key concepts
How a reporting group works
Lead entity
Holds shared AML/CTF policies, risk assessment, AMLCO.
Members
Adopt the lead entity's framework.
Joint accountability
Non-compliance by one member exposes the whole group.
Checklist
Lead-entity duties
- Maintain the shared AML/CTF program.
- Coordinate the risk assessment across members.
- Ensure consistent CDD across the group.
- Submit reports on behalf of group members where applicable.