An AML CFT Programme must set out how a business will conduct employee due diligence for senior managers, the AML CFT compliance officer and for any other employee who may be able to facilitate money laundering or terrorism financing.
The Programme must set out risk based systems and controls to determine -
How to screen existing employees
How to screen new employees
How to screen any employee whose duties change and
exposes them to the risk of facilitating money laundering or terrorism
financing
Screening processes for employees may include –
A criminal history
check;
Verification of
academic qualifications and professional memberships;
Verification of name,
address and date of birth;
Verification of
employment history over past 5 years;
Checks of directorships
and shareholdings;
Checks of bankruptcies
and directorship disqualifications;
