• whether the CEO and senior management of the company fully understands their obligations and AML/CFT responsibilities;
• whether the CEO and senior management receive regular AML/CFT training;
• the extent of regular management information on AML/CFT matters;
• whether the CEO or senior management approved the Company’s AML/CFT policy;
• the resources that the CEO /senior management have allocated to AML/CFT (human, IT, budgets etc.);
• whether the CEO has issued a policy statement confirming a commitment to AML/CFT; and
• whether a company wide AML/CFT compliance culture is promoted within the company.