Policies answer: "what?" |
A policy statement is written to address the main reason for its existence. As it relates to AML regulations, AML policies and procedures are directly linked to the mandatory guidelines. Policies lay out the regulations that your organization must comply with and internalizes these compliance requirements throughout the documentation. For example, a policy statement may suggest the following: "It is the policy of the company to report all large cash transactions to FINTRAC." This policy statement, in and of itself, does not provide guidance to management as to how to perform the task. In order to address the steps that should be taken, detailed procedures must be developed.
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Procedures answer: "how?" |
Detailed procedures are highly customized for your operation and may show significant differences from one organization to another depending on the people involved and the systems used. For example, one organization may use highly automated IT system which earmarks transactions for specific types of FINTRAC reports while another organization may have to use manual procedures to identify applicable transactions and submit the relevant FINTRAC reports. In addition, the number of people involved in the compliance process also dictates the level of required in the policies and procedures. For example, a large organization with multiple departments should develop step-by-step procedures explaining what each group and even each person should do in order to ensure compliance with AML regulations.
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Bottom line |
AML policies and procedures must include adequate content to address "what" and "how" questions. Any other relevant information management prefers to capture in the policies and procedures are considered to be guidelines. For example, excerpts from FINTRAC guidelines and appendices including sample forms and screenshots are considered to be reference material. Guidelines are optional and do not have to be captured in the policies and procedures.
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Need assistance? |
Because the AML policies and procedures require high level of customization and your organization may not have the prerequisite expertise in-house, you may need a certain level of assistance from professionals with AML experience. Depending on your situation and the complexity of your operation, your needs can range from a single advisory discussion to a more detailed development and implementation of your customized policies and procedures. If you are not sure as to what level of assistance you require, please feel free to give us a call for a free consultation. We can help you by answering your questions or assisting you with developing a bullet-proof road map to compliance.
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