(5) AML Officer
Compliance division must designate/nominate at least 1 staff as AML officers to:
A. Act as the liaison between the business/support units and compliance division.
B. Assist compliance division in its effort to raise awareness on money laundering issues by updating staff on the latest changes.
C. Facilitate the business/support units in their compliance with the relevant laws, regulatory and statutory requirement on money laundering.
D. Develop written AML/CFT compliance program for each business unit, which is approved by the chief compliance officer and by the president and ceo, and carry out checks to determine AML/CFT compliance with legal, regulatory and statutory requirements, internal policies and AML/CFT guidelines.
E. Conduct further investigation into report of suspected money laundering activities and provide recommendations to heads of business/support units on the validity of and the need for reporting to relevant authorities.
F. Serve as a ‘help desk’ to staff in the relevant business unit to answer question concerning application of AML/CFT policy and procedure in daily operational activities.
G. Accordance with the escalation/reporting process.
(6) Internal Audit Unit
Internal audit unit plays an important role in independently evaluating the risk management and controls, discharging its responsibility to the audit committee or a similar oversight body through periodic evaluations of the effectiveness of compliance with AML/CFT policy and procedure, as well as related staff training by:
a. Understanding how compliance requirements apply to operations and conducting test to ensure that procedures are followed. However, internal auditors need not be the experts on AML/CFT.
b. Reviewing the adequacy and effectiveness of the AML/CFT process in a business/support unit:
(a) KYC/CDD program.
(b) Customer acceptance policy.
(c) System for monitoring, identifying,investigating and reporting on suspicious money laundering transactions.
(d) Retention and maintenance of financial transaction document, as well as KYC/CDD documentation.
c. Reviewing the business/support units’ compliance with the policy.
d. Assessing overall effectiveness and whether the customer acceptance policy and KYC/CDD procedure are effective in view of AML/CFT objectives.
e. Monitoring and testing of compliance with the policies and procedure is the responsibility of the internal audit unit. The internal audit unit will also conduct reviews of exception reports to alert the compliance officer, bank management or the board of directors if it finds incidents of non-compliance