Do I need an AML/CTF Program?


Legal policies and the government’s rule of law are always a rising phenomenon. From businesses to workers on the road, you have to be careful no matter who you are. These policies are here to help you be a better citizen and aid the government in ruling a better country than before. One such policy these days is the AML CTF Program (Anti-Money Laundering/ Counter-terrorism Financing) that applies to financial entities, with one helping the government in a different way than the other. These policies are necessary these days to run a business that the government approves.


An AML/CTF program is made for reporting entities that engage in financial business services such as bullion, gambling, and digital currency exchange. These reporting entities must develop an AML program to show how they address money laundering and terrorism financing problems that their organisation can face through criminal minds. They must develop and record their policies, procedures, and operations to find, reduce and handle the money laundering and terrorism financing risks. A business such as gambling is especially prone to attracting these problems, so one needs to base an AML program on the risk accumulated. It is a precautionary measure above all.  

How is an AML Program developed? 

An AML program usually consists of two main parts, with two interacting bodies in function: The business and the customer. Or, more precisely, the internal problems and the external problems.

– For the internal problem or the potential careless policies, the operations and procedures are involved in picking out, handling, and reducing the potential threats that your entity can be vulnerable to. Some of its regulations are:

● A regular review of your business or organisation is done through risk assessment daily.

● A senior board management approval that consistently oversees the affairs taking place.

● Having an AML program officer at your office to curb the risks involved by evaluating the work in accordance with the obligations.

● An employee due diligence program that checks the employee’s profile before hiring. Employees can pose a risk, too, if not taken care of.

● An AML / CTF risk awareness training for all your employees so that they can recognise the risks instantly.  

– Part B is focused on dealing with customers and the procedures that go in for identifying them and their employers. Some customers are known as PEPs, too, meaning customers that are Politically Exposed Persons. These are recognised especially by reporting entities by following the rules below:

● The customer information that you consider verifies their claims of who they are or whom they work for and if these companies and organisations exist for real. Your process of this is important.

● What beneficial owners’ information you collect and check, and how you do this.

● Through what process do you conclude that your beneficial owners or customers are PEPs (Politically Exposed Persons)

● What is your response to bugs and discrepancies in your customer information, and is there a backup process of verification

● In what circumstances would you decide to collect additional information about a customer

Why should an AML Program be done professionally? 

The most important reason for this program to be done professionally is that there isn’t a particular handbook that you can use to document all businesses. The specificity of different organisations makes it difficult to apply the same template to all entities for anti-money laundering and counter-terrorism financing. Hire a professional and be free of the risks of money laundering and terrorism financing.