AML / CFT Programme Expectations
Money Services Businesses are inherently exposed to financial crime risk. Licensees are therefore expected to operate a practical and risk-based Anti-Money Laundering and Counter-Terrorist Financing programme that actively monitors transactions, customers, and counterparties.
Core AML / CFT Framework
Every licensed MSB should maintain a structured compliance environment.
Risk Assessment
Identify geographic, customer, and transaction risks relevant to the business model.
Customer Due Diligence
Verify identity, understand business purpose, and assess beneficial ownership.
Transaction Monitoring
Implement systems to detect unusual behaviour and suspicious transaction patterns.
Operational Controls
AML programmes should exist in practice, not just in documentation.
Sanctions Screening
Customers, counterparties, and beneficial owners should be screened against applicable sanctions lists.
Enhanced Due Diligence
Higher-risk customers or jurisdictions require deeper review and documentation.
Suspicious Activity Reporting
Internal escalation and reporting procedures should exist where suspicious behaviour is identified.
Record Retention
Customer and transaction records should be preserved for the legally required retention period.
Governance & Accountability
- Appoint a designated AML compliance officer.
- Maintain internal reporting channels for staff.
- Conduct regular staff training and awareness programmes.
- Maintain independent review or audit of the AML framework.
High-Risk Indicators
Transaction anomalies
Unexpected spikes in transaction volume or patterns inconsistent with the customer profile.
Jurisdictional risk
Exposure to high-risk countries without appropriate monitoring or controls.
Customer behaviour changes
Sudden change in activity type, transaction size, or frequency.
Unusual payment routing
Complex routing or layered transactions designed to obscure origin of funds.