Elements and Performance Criteria
- Research and analyse requirements for AML/CTF program development
- Analyse legislative and regulatory requirements relevant to AML/CTF policy and practice including specific requirements of the National Privacy Principles
- Evaluate the AML/CTF implications for the products and services offered by the organisation
- 1.3 Analyse and assess the organisation's AML/CTF program requirements and goals, considering the organisation’s nature, scale and complexity of business
- Research and assess other relevant guidance including industry codes and standards, sector counterparts and international regulators
- Collate and analyse organisational data and trends relating to AML/CTF activity and controls
- 1.6 Synthesise outcomes of research and analysis and brief relevant personnel on the implications of the findings for the organisation's AML/CTF program
- Design an AML/CTF program for an organisation
- Review outcomes of research and design a program for a new, redesigned or reconfigured AML/CTF program in consultation with key personnel
- Document a proposal for a new, redesigned or reconfigured AML/CTF program that includes consideration of resource allocations, assessment of risk and prioritised actions and timeframes
- Present proposal for a new, redesigned or reconfigured AML/CTF program, advocate benefits and secure approval from senior management and/or the Board
- Develop the AML/CTF program
- Oversee the preparation of draft policies and procedures and specifications for changes to system requirements
- Consult with stakeholders to seek input and feedback on new, redesigned or reconfigured AML/CTF program to ensure agreement and ownership
- Lead evaluation of feedback on draft policies and procedures and system requirements, and authorise changes
- Designate responsibility and accountability in job roles and/or organisational sections for ensuring compliance with aspects of the AML/CTF program
- Develop AML/CTF program goals and performance criteria
- Secure approval from senior management or Board for the new, redesigned or reconfigured AML/CTF program