Key personnel and AML/CTF Compliance Officer – fit and proper assessment including review of qualifications and experience.
Foreign jurisdictions – permanent establishments, operations and relationships and the practice in managing associated risks.
Internal and External Reviews – suitability of frequency
Screening Policy and Procedures – quality of screening and investigations
Privacy obligations – how the entity handles private and confidential information it collects
Beneficial Ownership Policy and Procedures – standard
Enhanced Customer Due Diligence – triggers and approach
Suspicious Matters – triggers, reporting and or management
Employees Training – suitability, content and frequency
Explanatory notes for applicants to better understand the expectations and requirements of the ARCPA Certification Program