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So your reporting entity implemented an AML/CTF program and everyone in the business committed to do what was needed. How much has changed in the intervening years since implementation and, more importantly, how do you monitor compliance with the program? Are you struggling with the roles set out in the three lines of defence? Whilst you may sit in line 2 are you dealing with the business and making decisions they should be making? Are you a part time compliance officer with a day job? What is your time allocation for the management of an AML/CTF program?
This program will work through the intricacies of managing all the moving parts of a program and looks at common issues found in AML/CTF programs.
Most programs were implemented in 2007 and, apart from changes around KYC, most programs have not moved down the maturity path. There has been, and continues to be, significant change. Has your program matured or is it still taking a minimalist approach? Have the board actually had any relevant training? When was the last time that you had an independent review? Was it actually independent? Does your risk assessment flow into your transaction monitoring?
Using real examples as case studies, this program is designed to help you understand:
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