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• Develop and maintain AML/CFT policies, manuals, and procedures to ensure alignment, including those from local authorities (e.g., NBC, CAFIU) and international standards.
• Develop and ensure effective execution of AML/KYC processes, including customer onboarding process, customer/employee/business partner due diligence measures, data maintenance, and on-going due diligence. Drive process improvements and ensure consistency across relevant teams.
• Manage and regularly update the institution’s ML/TF Risk Assessment covering customers, products, services, transactions, and delivery channels, and ensure effective application of the Risk-Based Approach (RBA), as well as periodic reports to the Board.
• Design, implement, and maintain a customer risk assessment framework to support risk classification, onboarding decisions, and ongoing customer monitoring.
• Act as the primary escalation point for AML/CFT issues, including customer onboarding decisions, high-risk classifications, and de-marketing considerations.
• Oversee transaction monitoring and investigations, ensuring timely and thorough review of alerts, suspicious activities, and internal referrals.
• Manage AML/CFT reporting obligations, including preparation and submission of Suspicious Transaction Reports (STRs), Currency Transaction Reports (CTRs), and internal compliance reports.
• Maintain a comprehensive AML/CFT incident register, documenting all internal cases, investigations, and regulatory reports.
• Develop and deliver AML/CFT training programs for employees, particularly front-line and compliance-related functions. Maintain records of training attendance and evaluate effectiveness.
• Coordinate AML/CFT audits and inspections (internal, external, regulatory), and ensure timely implementation of corrective actions based on audit findings.