Framework
DesignGovernance
Management body oversight, the Compliance Officer or MLRO role, independence and reporting lines.
Risk assessment
The business-wide risk assessment and customer risk scoring.
Policies and procedures
Completeness against current law, and readiness for the AMLR.
Training and records
Training coverage and record-keeping against retention rules.
Outsourcing and agents
Oversight of outsourced tasks, agents and distributors.



