Fundamentally, an AML/CFT program should be risk-based. Certain
aspects of a financial institution's business will pose greater
money laundering risks than others and will require additional
controls to mitigate those risks, while others will present a
minimal risk and will not need the same level of attention.
Depending on the size of the organization, the anti-money
laundering function may be managed as a dedicated/stand-alone
department, integrated into other corporate departments such as the
legal department or may be performed by people who have other compliance duties.
The AML/CFT program should establish minimum standards for the
enterprise that are reasonably designed to comply with all
applicable laws and regulations. It may be supplemented by the
policies and procedures of various lines of business or legal
entities that address specific areas, such as private banking,
trade finance, cash handling, institutional banking, wealth
management or investigations.
