As a designated service provider, you must ensure that you have a rigorous anti-money laundering/counter-terrorism financing policy in place, which includes the following:

• Conduct customer due diligence in compliance with their market and operating model, the nature and types of customers they serve, products they offer, and risk raised by their geographic location.
• Entities must determine the beneficial owners and take appropriate measures to verify their identity by using accurate and reliable documents, records, or information sources.
• All customer business relationships must be monitored on a regular basis to ensure that transactions are consistent and CDD is up to date.
• Implement appropriate internal policies and procedures for politically exposed persons, as well as ensure compliance with relevant record-keeping requirements including retention periods.
• Reporting entities must establish AML/CFT/CPF polices, processes, controls, responsibilities, and preventive measures that take into consideration their scale, nature of business, and operational complexities.
• Internal Risk Assessment Reports (IRAR) for assessing the effectiveness of existing AML/CFT policies, controls, obligations and preventive measures including STR/CTR

Each registered entity should consider the unique nature of its market, corporate structure, clients and transaction types, and other factors when adopting initiatives and procedures to ensure their effectiveness. IRAR is responsible for identifying, assessing, and comprehending ML/ TF/ PF risks at the entity level for consumers, products, facilities, distribution platforms, technologies, and employees etc.

All AML/CFT programs must be risk-based. The risk assessment serves as the foundation for your entire anti-money laundering/counter-terrorism financing program. Your program must demonstrate clearly the connections between defined risks and the processes, practises, and controls that address those risks.