At a minimum, a reporting entity is required to meet the five (5) established pillars of anti-money laundering and countering terrorist financing. Section 19 of the Act and Amendments thereto provides for the following:

• Appoint a compliance officer who shall be responsible for ensuring the reporting entity’s compliance with the requirements of this Act
• Establish and maintain internal policies, procedures, controls and systems to-
  • Implement the customer identification requirements
  • Implement record keeping and retention requirements
  • Implement the monitoring requirements
  • Implement the reporting requirements under Section 18
  • Make its officers and employees aware of the law relating to combating money laundering and terrorist financing
  • Make its officers and employees aware of the procedures and policies adopted by it to deter money laundering and terrorist financing; and
  • Screen persons before hiring them as employees.
• Establish an independent audit function with adequate resources to test its anti-money laundering and combating of terrorist financing procedures and systems; and
• Train on an on-going basis, its officers, employees and agents to recognize suspicious transactions and establish on going employee training to ensure that employees are kept informed of new developments, including information on current money laundering and financing terrorism techniques, methods, and trends and clearly explain to officers, employees and agents, all aspects of anti-money laundering and countering the financing of terrorism laws and obligations in particular those relating to customer due diligence and suspicious transaction reporting.
• Identify and assess the money laundering or terrorist financing risks and take appropriate measures to management and mitigate those risks which may arise in relation to -
  • The development of new products and new business practices including new delivery mechanisms; and
  • The use of new products, business practices or the use of new or developing technologies.

Further, for the purpose of monitoring compliance, with the provisions of this Act, reporting entities are required to be registered with the Financial Intelligence Unit in the manner and form as the Director may determine. See other Obligations of a Reporting Entity - Issue No.9 of the Financial Intelligence Unit.