AML/CFT/CFP POLICIES & PROCEDURES COMPLIANCE PROGRAM

AML/CFT/CFP Policy & Framework:

• Development
• Enhancement
• Template
• Gap Assessment

AML/CFT/CFP Risk Management Program

• Develop
• Enhance
• Conduct (annually and semi-annually or as per required)
• Business-wide ML/FT/FP Risk Assessments.
• Customer-specific Risk Exposure and Mitigation Strategies.
• ML/FT/FP Risk Registers and Risk-based Approaches.

Customer On-boarding / Know Your Customers (KYC)

• Customer Relationship Management System
• KYC Remediation / KYC Look back
• Transaction Monitoring Look back
• Suspicious Activity/Transaction Report (SAR/STR) Look-Back/Investigation
• Enhance Due Diligence (EDD)
• Sanctions False Positive Remediation
• Sanctions Gap Assessment
• PEP Remediation
• Assistance in Selecting and Integrating:

1. 1. Customer On-boarding Systems
   2. Transaction Monitoring Software Applications
   3. Sanction Screening Solutions
   4. Document Management and Record Keeping System
   5. Regulatory Compliance Database

• Implementation:
  • Set-up program per each department

Compliance Officer / MLRO Function:

• On-demand support for MLCO/MLRO tasks
• Pre-selection of MLCO/MLRO candidates
• MLCO/MLRO mentoring and shadowing program

Regulatory Readiness & Supervisory Audit Visit Preparation

• AML/CFT/CFP investigations, remediation advice & audit preparation
• Reviewing controls & identifying compliance gaps
• Support with regulatory filings & documentation

AML/T/CFP Training & Awareness Program

• Annual Training for:
  1. Front-Line Staff
  2. Back-Office Staff
  3. Board of Directors
  4. Senior Management
• Specialized Training for:
  1. New Employees
  2. Compliance Staff
  3. Risk Management Dept. Staff