AML & CFT Advisory, Policy & System

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Periodically analyze the risk assessment of MLTF and WMDP related to their Customers, countries or geographic areas, products, services, transactions or distribution networks once a year. Compiling, updating, and propose policies and implementation procedures the AML CFT and WMDP programs that have been prepared to manage and mitigate risks based on risk assessment as referred to in the point 1, to request the consideration of the Board of Directors;
Ensure that there is a system that can identify, analyze, monitor and provide reports effectively regarding the profile, characteristics, or patterns of transactions made by the Customer;
Ensure that the policies and procedures prepared as referred to in point 2, are in accordance with changes and developments which include among others products, services and technology in the financial services sector, activities, business scale, business complexity, business characteristics, Bank transaction volume, and/or MLTF and WMDP mode;
Ensure that the forms related to the Customer have accommodated the data needed in the implementation of the AML CFT and WMDP programs;
Monitor the Customer's account and the execution of the Customer's transactions;
Evaluate the results of monitoring and analysis of customer transactions to ensure the presence or absence of Suspicious Financial Transactions, Cash Financial Transactions, and/or financial transactions of fund transfers to and from abroad;
Administer monitoring and evaluation results;
Ensuring the updating of customer data and profiles as well as customer transaction data and profiles;
Ensure that business activities that have a high risk of MLTF and WMDP are effectively identified in accordance with the Bank’s policies and procedures and the provisions referred to in this Financial Services Authority Regulation;
Ensure that there is a good communication mechanism from each related work unit to special work units or officials responsible for the implementation of the AML CFT and WMDP programmes by maintaining the confidentiality of information and paying attention to anti-tipping-off provisions;
Supervise the implementation of the AML CFT and WMDP programmes to the relevant work units;
Ensure the identification of high-risk areas related to the implementation of the AML-CFT and WMDP programmes with reference to laws and regulations and adequate sources of information;
Receiving, analyzing, and compiling reports on Suspicious Financial Transactions and/or Cash Financial Transactions submitted by work units;
Prepare and submit reports on Suspicious Financial Transactions that have been approved by Compliance Director approval, prepare and submit Cash Financial Transactions, and monitoring submission of Financial transactions of fund transfers to and from abroad, and ensuring all reports have been submitted in timely manner;
Monitor periodically and ensure follow-up of Terrorist List and WMDP is in accordance with laws and regulations regarding the prevention and eradication of TF and regulations regarding the prevention and eradication of WMDP Monitor, analyze, and recommend training needs regarding the implementation of the AML CFT and WMDP programmes for Bank employees;
Ensuring that all activities for the implementation of the AML CFT and WMDP programmes are carried out properly; and Perform other tasks for the implementation of the AML CFT and WMDP programmes.

• Performing AML CFT and WMDP Testing by periodical basis.
• Performing AML CFT and WMDP Risk Assessment.
• Conducting AML CFT and WMDP training for targeted participants.
• Assisting auditor on AML CFT and WMDP matters.
• Become advisory for AML CFT and WMDP regulation to Business Unit Performing review and advisory related New and Revision of Policy and Procedure, new product, new system, system enhancement and new process to Business Unit.
• Supporting duties in receiving, analysing, and preparing Suspicious Financial Transaction reports and/or financial transactions conducted in cash delivered by the working units Reporting Cash Transaction, Suspicious Transaction, APOLO, SIGAP, SIPENDAR and any ad hoc report required by the regulator.
• Supporting duties in handling letters, inquiring, etc. from the regulator Monitoring implementation of CDD and EDD periodically or trigger event review.
• Others duties assigned by AML CFT and WMDP Head / Compliance Director related with AML CFT and WMDP matter