News

CFTC guide on how to assess the effectiveness of their AML/Compliance program.

21/09/2020

The US Commodity Futures Trading Commission (CFTC) has published a 3 pager which firms can use to assess the effectiveness of their AML/Compliance program.

This is the link: https://bit.ly/35IyosU

Here is a quick overview:

  1. Prevention
  • Are policies written and implemented?
  • Were staff trained on compliance procedures?
  • Were deficiencies identified and resolved?
  • Are there adequate resources?
  • Is governance oversight formalized?

  1. Detection
  • Is there ongoing surveillance and periodic monitoring?
  • Are there internal reporting processes/procedures?
  • Are there automated suspicious activities checks?

  1. Remediation
  • Are breaches effectively resolved?
  • Are remedial actions taken, including disciplinary action (if necessary)?
  • Are procedures, checks and controls amended to reduce the risk of recurrence?