Areas concerning AMLCFT Framework

Risk

1. Governance
2. Ownership
3. Responsibility
4. Communication

Risk-Based Approach (RBA)

There are three areas under RBA:

Customer Onboarding

1. Risk profiling
2. Name screening
3. Customer Due Diligence (CDD)
4. Customer Acceptance

Transaction Monitoring

1. Identification of suspicious transactions
2. Tracking of suspicious transactions
3. Investigation of alerts generated
4. Justification of threshold that generates alerts
5. Filtering false positives

On-going monitoring

1. On-going CDD
2. On-going name screening
3. Enhanced customer due diligence
4. New and existing product and services due diligence
5. Customer behaviour profiling

Skills & knowledge of staff

1. Training
2. Resources provided
3. Succession planning

Management of information

1. Case management workflow of reviewing alerts
2. Reporting to senior management
3. Case management workflow of reporting positively identified suspicious alerts internally and externally.

Continuous improvement and innovation

1. Reviewing of client profiling methods
2. Monitoring and detection of alerts as risk factor changes
3. Operational risk review methods
4. Best practice methods
5. Product life cycle for money laundering or terrorist financing vulnerabilities
6. Customer experience over the entire product life cycle
7. Analytic methods
8. Reducing false positives by increasing artificial intelligence/algorithms.