The most important aspect of an effective program for anti-money laundering (AML) and combating the financing of terrorism (CFT) is people. It is critical for an organization to have staff who are knowledgeable and experienced and continuously receive training.
The best policies, procedures and software in the world are meaningless without the proper personnel to implement the policies and analyze the data and reports generated by the software. The staff then needs the proper tools to effectively execute their responsibilities. A customer identification program, transaction trend-monitoring system and case management program are the essential tools of an AML/CFT compliance program -- which must align with tailored risk-based policies and procedures. Every institution is different, so each program will differ from other programs.
Moving forward, the program must be adaptable because there always are new money laundering and terrorist financing techniques arising -- for all institutions, no matter how small or "tight-knit" the customer base may be. In addition, countries are updating current, and implementing new, laws and regulations to meet international guidances and address new methodologies. All this has to be accomplished in a global economy that is experiencing budget cuts, especially in the so-called cost centers, such as compliance and risk management. But thankfully, many institutions realize the negative effect cost cutting in compliance would have and the increased reputational risk that is at stake. With new and old threats, such as virtual/digital currency, stored-value cards and trade-based financing, the staff must receive ongoing training and institutions must ensure they are knowledgeable.