Who Owns What? Defining Roles in Your AML/CTF Program

Ever feel like your AML/CTF program is a bit of a free-for-all?   Well, unclear roles and responsibilities are a major reason programs fall short.  Here’s a breakdown of who typically owns what in a strong AML/CTF program, along with some practical tips:

The Executive Suite: Setting the Tone from the Top ‍

Management: Ultimately responsible for ensuring the program’s effectiveness. They allocate resources, establish risk tolerance, and champion the AML/CTF culture.

Board of Directors: Provides oversight, ensuring management has the resources and implements the program effectively.

The AML/CTF Team: Your Compliance Champions ?

AML Officer (AMLO): The program’s quarterback, overseeing day-to-day operations, customer due diligence (CDD), and suspicious activity reporting (SAR).

Compliance Officer: Works closely with the AMLO, ensuring adherence to regulations and internal policies.

Analysts: Conduct CDD, monitor transactions, and investigate suspicious activity.

The Business Units: Everyone Plays a Part!

Frontline Staff: The first line of defense, identifying suspicious activity during customer interactions.

IT Department: Ensures systems and data are secure and support AML/CTF efforts.

Making it Work: Practical Tips

RACI Matrix: Develop a clear "Responsible, Accountable, Consulted, Informed" (RACI) matrix outlining roles and responsibilities for each AML/CTF task.

Training & Communication: Regularly train staff on their AML/CTF roles and keep everyone informed about program updates and risks.

Reporting Lines: Establish clear reporting lines for suspicious activity and concerns.

By clearly defining roles and fostering a culture of ownership, you can ensure your AML/CTF program is effective and protects your organization from financial crime.  

Let’s not forget, AML/CTF is a team effort!