Category:
AML/CFT Policies Controls And Procedures PCPs
The Compliance Officer (CO) and Money Laundering Reporting Officer (MLRO), who are senior officers within the organisation, play a key role in fulfilling the aforesaid obligation.
They need to continuously monitor the implementation of the PCPs, regularly review, conduct gap analysis, propose updates to the PCPs and report their recommendations to the senior management & the board of directors for approval.
In addition, Reporting Persons are ultimately responsible for their PCPs even if a third party assisted them in the drafting or reviewing. Reporting persons, their relevant officers and the Board of Directors have to be well across the PCPs and ensure adherence to same.