What is the AML/CFT Policy Manual add-on?
The AML/CFT Policy Manual is a practical policy document for a TCSP licensee. It sets out the client’s approach to AML/CFT governance, risk assessment, customer due diligence, ongoing monitoring, suspicious transaction reporting, record keeping, screening, staff training and independent review requirements.
When is it useful?
- The client does not have a formal AML/CFT policy manual.
- The existing policy is outdated or not aligned with current TCSP expectations.
- The independent review identifies gaps in policy coverage or implementation.
- The client wants a more structured document for internal compliance records.
What areas may be covered?
The manual may cover introduction and legal framework, roles and responsibilities, institutional and customer risk assessment, CDD, EDD, PEPs, higher-risk situations, ongoing monitoring, STR, record keeping, screening procedures, employee screening, staff training, independent audit function and cooperation with regulators and law enforcement agencies.
Not a standalone template shop
The policy manual is generally provided as part of a review or implementation engagement. It is adapted to the client’s TCSP business model, governance structure and risk profile rather than sold as a generic template.