(3) branch manager/department head/branch manager/department head are required to:
A. continuously and actively keep abreast of the latest changes in the regulatory requirements;
B. update compliance and internal audit of any AML/CFT changes or key concerned issues relating to AML/CFT and ensure compliance with these requirements;
c. Ensure that bank staffs perform regular reviews of transaction involving high risk customer, products and services; review and update the risk assessments as necessary;
d. Ensure that staff under them follows reporting, record-keeping and documentation requirements.
(4) Compliance division
Compliance division has important responsibilities in evaluating and ensuring adherence to KYC/CDD policy and procedure. As s general rule, the compliance division should develop and regularly review adherence to the bank’s AML/CFT policy and procedure, including regularly updating to reflect new legal and regulatory requirements and changes. Its responsibilities should include ongoing monitoring of the quality and effectiveness of the procedures, and helping staff and management solve issues in relation to implementation and making decisions concerning risk assessment, and serving as a ‘help desk’ whenever staff have questions about procedures or actions that should be taken.
It is the responsibility of all bank staff to immediately alert the compliance officer and/or bank management whenever any incident of non-compliance is noticed. Failure to do so should be appropriately sanctioned. Serious and immediate sanctions should be applied against any staffs who fail to comply with AML/CFT policy and procedure.
The roles of compliance division are as follows:
A. Establish and issue written policy/procedure on AML/CFT which approved by the board of director. Distribute the policy and procedures to branches and all bank staff ensuring that every employee has a copy.
B. Promote awareness of
(a) Laws, regulations and statutory requirements relating to money laundering as well as any related amendments.
(b) New trend in money laundering.
(c) New trend in banking industry on money laundering control.
c. develop and organize regular AML/CFT training program for the bank in which all staff must participate.
d. disseminate updates on laws, regulatory, statutory requirement, policies and quidelines as well as articles and reference materials with respect to money laundering in the bank.
e. review waivers granting in accordance with the customer acceptance policy.
f. support efforts of all bank staff to understand and comply with all policies and procedures, this means serving as a help-desk on day-to-day questions staff may have in daily operational activities.
g. maintain records and unreported unusual/suspicious transactions. For transaction, which were not reported to the AMLO (anti-money laundering office), keep records documenting the reasons why it was decided not to report the transaction.