Compliance program requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations require:
appointing a compliance officer who is responsible for implementing the program;
developing and applying written compliance policies and procedures that are kept up to date and, in the case of an entity, are approved by a senior officer;
conducting a risk assessment of your business to assess and document the risk of a money laundering offence or a terrorist activity financing offence (ML/TF) occurring in the course of your activities;
developing and maintaining a written, ongoing compliance training program for your employees, agents or mandataries, or other authorized persons;
instituting and documenting a plan for the ongoing compliance training program and delivering the training (training plan); and
instituting and documenting a plan for a review of the compliance program for the purpose of testing its effectiveness, and carrying out this review every two years at a minimum (two-year effectiveness review).
Ethidex has a Regulatory Module, prepared and updated quarterly by our lawyers, to capture MSB AML/ATF requirements. Together with our Compliance Office software, this Module can form the basis for an AML/ATF Compliance Program.
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