Management need to be satisfied that the risk of their business being used for money laundering or terrorism financing has been minimised and that regulatory requirements to develop and maintain a compliance programme has been discharged.

Communication of policies and procedures to prevent money laundering and terrorism financing underpin all other anti-money laundering strategies.

The objective of maintaining an AML CFT policy is two-fold –

• To communicate the intent to management and staff internally
• To provide evidence to an external party (such as a supervisor) of the intent to comply.

Procedures should not be seen as a 'paper only' approach. Day-to-day practices must meet requirements of the compliance programme.