AML/CTF Compliance Officer, Part 1: Governance, Accountability and Risk

About this course

Being an AML/CTF Compliance Officer is not an administrative appointment. A reporting entity can hold comprehensive policies, capable technology and experienced operational teams and still carry significant weaknesses. Controls exist on paper but do not operate. Monitoring rules do not address the risks in the risk assessment. Part 1 is about the foundations that determine whether you can see any of that. Three modules. The first covers the governance framework, where your responsibility begins and ends, the authority and independence the role requires, and what fit and proper actually means. The second covers the ML/TF/PF risk assessment: what it must consider, the difference between inherent risk, controls and residual risk, when it should be reviewed, and how to use your own internal information to challenge a rating that no longer reflects reality. The third covers oversight of the program itself, including design versus operating effectiveness, exceptions that quietly become permanent, outsourcing, and why a green dashboard is not assurance. Part 1 is the prerequisite for Parts 2 and 3, and the right starting point for anyone newly appointed. It also stands alone for governing body members and senior managers who need to understand what they should be receiving and questioning. It assumes familiarity with the basics of the regime and concentrates on oversight, evidence and effective challenge.

Curriculum