5 steps for the appointment of persons responsible for the implementation of the AML/CTPF Law requirements

Taking into consideration the fact that according to Article 10 of the AML/CTPF Law, within 30 days after obtaining the status of the subject of the law, the entrepreneur must appoint the person responsible for fulfilling the requirements of the law, it is worth to:

1. Spend some time structuring the internal control system, paying special attention to the organization of the customer KYC, due diligence and decision-making processes.
2. Ensure compliance assessment of the responsible person, as well as other employees who will be involved in the execution of the AML/CTPF law requirements, i.e., reputational, criminal record check.
3. Appoint a member of the senior management (board) as the AML/CTPF policy approver and supervisor of the compliance process.
4. Decide who will be entrusted to develop the AML/CTPF policy and related procedures of the company. This is the stage where an optimal customer research process can be developed.
5. Appoint the employees responsible for customer research who will ensure the implementation of the AML/CTPF policy and related procedures.

A well-structured AML/CTPF policy and elaborated procedures are like a solid foundation for a house. A well-thought-out dividing of functions and a properly chosen responsible person are like straight walls and a safe roof over your head. Think of developing your company's internal control system as building your own house and remember that you may hire a different contractor for each stage.

Divide the functions so that all the work that can be standardized is done by the responsible employee with lower competence, and the decisions that imply higher risk are made by the more experienced and competent employee.

Atbilst team