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What should PCPs include?

Category: AML/CFT Policies Controls And Procedures PCPs

The documented PCPs should provide a clear approach on how the reporting person shall fulfil its AML/CFT obligations under the relevant Acts, Regulations and Guidelines. These include, amongst others:

  • Risk Assessment, Mitigation & Monitoring;
  • Customer Due Diligence, including identification of Beneficial Owners;
  • Dealing with High-Risk relationships (e.g. PEPs);
  • Role of Key Officers such as Compliance Officer and Money Laundering Reporting Officer (MLRO);
  • Suspicious Transaction Reporting;
  • UN Sanctions List Screening & Reporting;
  • Employee Screening & Training;
  • Record Keeping; and
  • Independent Audit & Review of PCP
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