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:

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?

2. Detection

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

3. 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?