Senior management in each country has ultimate responsibility for ensuring the existence and an operational effective AML/CTF compliance goverence framework including suspicious activity monitoring and reporting. Senior management in each country must also ensure adhereance to implementation of this Policy and in particular for:
• incorporating the requirements of this Policy into procedures as applicable;
• requesting advice from Compliance in its respective country on any exception, deviation and waiver requests;
• provide for adequate controls and approval for higher risk customers, transactions and products, as necessary, such as transaction limits or management approvals; and
• designate an individual or individuals at senior management level as the Money Laundering Reporting Officer (“MLRO”) responsible for managing AML/CTF risk management and compliance, who:
- is/are independent of the activities being monitored;
- has timely and unrestricted access to customer documents and any relevant information;
- enable the timely identification of reportable transactions to the local regulator as well as to senior management and ensure accurate filing of required reports; and
- is to act as the main point of co-ordination with the local regulatory body.