Anti-money laundering programme guidelines
An anti-money laundering (AML) programme should include, but is not limited to the following:
- A Brief description of the practice, company profile and history.
- Designate the responsibility of management of the firm in respect of compliance with the Financial Intelligence Act (FIA) and the execution of the AML programme.
- Appointment of Money Laundering Compliance Officer (MLCO), indicating responsibilities and functions.
- The identified areas considered to be vulnerable to Money Laundering (ML) based on the results of the risk assessment done by the firm taking into consideration the following:
c) Geographical areas
- The procedure/policy for the establishment and verification of client/customer identity.
- The procedure/policy on information to be kept and stored for record keeping purposes by the
- The procedure/policy for effective on-going monitoring systems to enable staff to recognise potentially suspicious and unusual transactions or series of transactions.
- The procedure/policy for Suspicious Transaction Reporting (STR) to be reported internally to the MLCO.
- The controls management will rely on to ensure that staff adheres to the AML programme.
- The procedures/policy that will be used to ensure a high standard of integrity of the law firms employees.
- The system that will be in place to evaluate the personal, like employees financial history.
- On-going training programmes, such as Know Your Customer (KYC) programmes and instructing staff with regard to responsibilities in terms of this Act.
- A independent audit function to check compliance with those programmes.
- Internal rules and disciplinary steps to be followed against non-compliance with the Act by staff members.
- The procedures/policy to implement the programmes at all the branch offices in Namibia.