How to assess risk and demonstrate your AML/CTF programme effectiveness.
30/06/2021
The Wolfsberg Group is pleased to publish its statement setting out how Financial Institutions (FIs) can assess risk in defined priority areas and demonstrate their Anti-Money Laundering/Combatting Terrorist Financing (AML/CTF) programme effectiveness. The document builds on the Group’s prior effectiveness statements to underline that the starting point for an effective AML/CTF programme should be an understanding of the priority risks identified by countries or supra-national bodies in their own assessments of AML/CTF risks and the applicability of those risks to the FI.
The Group believes that an FI’s effectiveness related to designated priorities or the AML/CTF programme overall should be measured based on its compliance with law and regulations, how it is designed to provide highly useful information to government authorities in defined priority areas, and how the FI builds and maintains a reasonable and risk-based set of controls to mitigate the risks of the FI being used to facilitate illicit activity.
The Group remains committed to further dialogue with policy makers, supervisors, law enforcement agencies and other stakeholders on effectiveness in AML/CTF in order to achieve our shared goal of fostering the increased effectiveness of the global financial crime risk management framework.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.