Beyond the Policy: Making Your AML/CTF Program Operational Reality
Many businesses approaching the Tranche 2 reforms focus on one thing: writing the AML/CTF Program document. While this is a critical requirement, it's only the first step. The real challenge—and where many fail—is translating that document from a shelf-ready policy into an operationally embedded framework that is practical, pragmatic and cost-effective.
The "Knowing-Doing" Gap in AML Compliance
Your team might know the policy, but will they follow it when under pressure to close a property deal or onboard a key client? Common failure points include:
Rushed Customer Due Diligence (CDD) & Risk Assessments: A sales agent, eager to secure a listing, collects minimal ID information, rushes through the client and transaction risk assessment without truly identifying the potential risk profile of client and transaction and doesn’t verify the client's source of funds.
Ongoing Monitoring: A lawyer, focused on complex legal work, fails to spot a red flag in a trust account transaction because there's no clear process or reporting mechanism.
Missed red risk flags or trigger events: An employee fails to identify elevating risk factors associated with a client or transaction in their risk assessment due to a basic or non-existent risk rating methodology which does adequately capture the inherent risks of their customer base and services.
Bridging the Gap: From Document to Doing
Process Integration: Map your AML obligations directly onto your existing workflows.
For a real estate agent, this means CDD checks are a mandatory step before the listing agreement is signed.
For a lawyer, it means a client and matter risk assessment is built into the CRM or matter management system.
Leverage Technology If Possible: Many soon to be regulated Tranche 2 businesses will conduct mainly manual checks due to cost considerations. If resources allow, try and use technology for identity verification, PEPs and sanctions screening, and even basic transaction monitoring. This improves onboarding efficiency, reduces time, human error and your compliance burden.
Practical, Role-Based Training: Move beyond reading the policy. Train your front-line staff with real-world scenarios they will face. "What do you do if a client refuses to provide source of wealth information?" or "This is what a suspicious property transaction might look like."
Clear Accountability & Empowerment: Ensure every team member knows their role and is empowered to pause a transaction if compliance isn't met. This might mean a complete culture shift of the business which must come from the top.
How an AML Consultant Adds Value Here
An experienced consultant does more than write a policy. They help you:
Conduct AML process design workshops to integrate controls seamlessly.
Advise on cost-effective AML technology that fits your practice.
Develop and deliver bespoke AML training that resonates with your staff.
Make your compliance program a living, breathing part of your business. Book a no-obligation free 30-minute consultation to see how we can assist you making your AML/CTF Program work for you.
