What is an AML/CTF program?

The core document

An AML/CTF (Anti-Money Laundering and Counter-Terrorism Financing) program is a tailored set of internal rules, policies, and procedures. It is not an off-the-shelf template; it must be built specifically for how your business works.

Part A: General risk management

This section focuses on identifying, mitigating, and managing the overall money laundering risks your business faces. It covers things like employee due diligence, staff training, and the appointment of an AML/CTF compliance officer. It is essentially your master risk manual.

Part B: Customer due diligence

This section dictates how you interact with specific clients. It outlines the exact steps and documents required to identify customers, understand who actually owns corporate clients (beneficial owners), and how to verify that information.

Board approval

A compliant AML/CTF program must be reviewed and officially approved by your governing board or senior management. This ensures absolute accountability starts at the top of the organization.