Developing an AML CFT programme is the second obligation that must be completed prior to the full implementation of the Act (the first is the AML CFT risk assessment). 

In developing a programme businesses need to also establish a culture in which employees are aware of their responsibilities.   

The programme will set out the resources, processes, procedures, systems and controls the business has allocated to ML TF risks.  Responsibility for ensuring the programme is adequate and that it is implemented rests with senior management.   

Before deciding what systems and controls to install, a business must have completed an assessment to determine the risks of its business or its services being used for money laundering or terrorist financing, or the risks of its clients and their counterparties being involved in such activities. 

An effective programme will protect the business against regulatory penalties or reputational damage. It should therefore be approved at the most senior level.   Those approving the programme should have a good understanding of the risks otherwise the ability to measure the effectiveness of the controls will be lost. 

On an ongoing basis senior management must ensure that the programme continues to reflect the current environment.