CFTC guide on how to assess the effectiveness of their AML/Compliance program.
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:
- Are policies written and implemented?
- Were staff trained on compliance procedures?
- Were deficiencies identified and resolved?
- Are there adequate resources?
- Is governance oversight formalized?
- Is there ongoing surveillance and periodic monitoring?
- Are there internal reporting processes/procedures?
- Are there automated suspicious activities checks?
- 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?