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:
- 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?
- Detection
- Is there ongoing surveillance and periodic monitoring?
- Are there internal reporting processes/procedures?
- Are there automated suspicious activities checks?
- 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?
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.