Wednesday, October 17, 2012

Cost Effectiveness Model for CFT Regime

Ideally, an effective AML-CFT Compliance Programmes must be designed to address both the "costs" and "effectiveness" elements of the programmes. Cost effectiveness model may include evaluating the following: 1. the risks specifically posed by the products and services that one's business offers; 2. the type of customers that that business attracts; 3. the methods in which the products are delivered; 4. the geographies linked to the underlying transactions; 5. the vulnerabilities that the business poses to the risk of facilitating money laundering or terrorism financing; 6. the compliance programme to include details of the policies, systems and controls to manage and monitor the risks presented. 6. these controls to include the means for detecting suspicious transactions and frequency of customer due diligence. By applying a risk based approach, one can determine if a business is overcommitting resourcing to areas of low to medium risk.