AML/CFT Procedures – Development and Implementation
An AML/CFT procedure is an internal document that sets out how an organisation identifies risk, verifies customers, analyses transactions, escalates cases and fulfils its AML/CFT obligations. At Dueveris AML, we develop and implement procedures tailored to your business activity, customers and actual operating processes – so they are not only compliant, but also practical for day-to-day use.
SPEAK WITH AN EXPERT ABOUT AML/CFT PROCEDURESDoes Your AML/CFT Procedure Reflect How Your Business Operates Today?
An AML/CFT procedure should reflect how your organisation actually works – from customer verification and alert analysis to escalations and reporting. When the document has not kept pace with change, or the team does not use it in practice, it requires review.
It is worth reviewing when:
The Procedure Was Not Updated After a Business Change
The company has launched a new product, sales channel or market, or now serves a different customer group than when the procedure was prepared.
The Team Has to Interpret the Rules Independently
The procedure does not clearly explain what to do in a real case or when escalation is required.
Roles and Decisions Are Unclear
It is unclear who is responsible for KYC, alert analysis, approval of higher-risk customers or reporting.
Processes Operate Differently Than Described in the Document
KYC, KYB, monitoring or reporting are carried out according to team practice rather than the procedure.
Tools or the Process Delivery Model Have Changed
Outsourcing, a new system or a different allocation of responsibilities has been introduced, but the procedure has not been updated accordingly.
An Audit, Inspection or Compliance Review Is Approaching
The organisation needs assurance that its operating rules are current, understandable and demonstrable in practice.
An AML/CFT Procedure Is Not a Copy of the Law
A well-designed procedure does not simply repeat legal obligations. It shows clearly who should act, when and how within your organisation – from customer verification to case escalation and reporting.
| AML Template | Dueveris AML Procedure |
|---|---|
| A general document for many businesses | Tailored to the business model |
| Description of obligations | Clear operating rules for the team |
| No practical roles or decisions | Defined roles, responsibilities and escalations |
| Detached from actual processes | Connected to KYC, monitoring and reporting |
| A document prepared for inspections | A document used in day-to-day work |
What Does an AML/CFT Procedure Cover?
An AML/CFT procedure sets out how an organisation identifies risk, makes decisions and documents actions in day-to-day operations.
AML/CFT Risk Assessment
Zasady oceny ryzyka organizacji, klientów, produktów, kanałów i relacji biznesowych.
KYC, KYB and Beneficial Ownership
Data requirements, customer-verification methods and rules for updating information.
Higher-Risk Customers
Criteria for enhanced due diligence, additional documentation, approvals and monitoring.
PEP and Sanctions Screening, and Match Analysis
Rules for handling potential matches, escalations and documenting decisions.
Transaction Monitoring and Alerts
Rules for analysing alerts, reviewing customer context and determining next steps.
GIIF Reporting
Case assessment, approval paths, data collection and confidentiality requirements.
Documentation and Registers
Rules for documenting decisions, retaining information and ensuring completeness of records.
Roles, Training and Internal Controls
Allocation of responsibilities, breach-reporting rules, quality assurance and team capability development.
How Does Dueveris AML Develop and Implement an AML/CFT Procedure?
We develop procedures based on your actual business model, risk profile and the way your team works. The goal is not to prepare a document for signature, but to create rules that can be applied in day-to-day cases.
1. Understanding Your Organisation
We analyse your business model, customers, products, sales channels, systems and current AML/CFT processes.
2. Identifying Risks and Gaps
We identify areas that require structure and where current rules do not reflect operational practice.
3. Designing the Operating Model
We define roles, responsibilities, approval levels, escalation paths and decision-documentation rules.
4. Drafting the Procedure
We prepare the document in language that is clear to the people who will use it.
5. Creating Supporting Materials
We prepare forms, checklists, registers and instructions needed to apply the procedure.
6. Implementing the Procedure with the Team
We walk through the operating rules, key scenarios and how to use the document in practice.
Developing a Procedure Is Not the Same as Implementing It
A procedure alone does not change how people work if the team does not know when to use it, who makes decisions or how actions should be documented. Implementation translates the rules set out in the document into day-to-day practice.
Procedure
Defines operating rules, roles, responsibilities and escalation paths.
Working Tools
Include forms, checklists, registers and instructions that support process delivery.
Team Practice
Requires discussion of real scenarios, training and verification that the rules are being applied correctly.
AML/CFT Procedure, Risk Assessment or Audit?
These services address different needs. They can work together, but each supports a different stage of building and maintaining an effective AML/CFT framework.
| Organisational Need | Best Solution |
|---|---|
| Define operating rules, roles and escalation paths | AML/CFT Procedure |
| Identify risks related to the business, customers and products | AML/CFT Risk Assessment |
| Assess whether the process works effectively in practice | AML/CFT Audit |
| Provide ongoing AML/CFT oversight and management decision support | External AML Officer |
A procedure defines how to act. A risk assessment identifies where attention should be focused. An audit checks whether the rules are actually being applied.
What Does a Well-Implemented AML/CFT Procedure Change?
A well-implemented procedure structures the team’s day-to-day work. Everyone knows what information to collect, when additional analysis is required, who makes decisions and how actions should be documented.
As a result, the organisation makes more consistent KYC, KYB and monitoring decisions, routes cases to the appropriate escalation path more quickly, and reduces the risk of relying on informal arrangements.
The procedure also becomes a practical reference point for training, quality assurance, audits and AML/CFT inspection readiness.
Need an AML/CFT procedure that structures real team decisions and actions?
Let’s discuss a procedure tailored to your business, customers, processes and risk profile.
Email Us
office@dueverisaml.pl
