AML / CFT due diligence and related matters – focus note 3

Various FATF Recommendations are considered in order to provide the context for the analysis set out below, specifically in respect of the following: Customer due diligence (CDD) (Recommendation 10), record keeping requirements (Recommendation 11), wire transfers (Recommendation 16), reliance on third parties (Recommendation 17), internal controls (Recommendation 18), reporting requirements for suspicious transactions (Recommendation 20) and guidance and feedback (Recommendation 34). The FinMark Trust country reviews of the regulatory requirements imposed in the SADC region indicates that all countries that participated in the study have core legislation in place to control ML/TF, and most also have subordinate legislation relating thereto. This reflects the progress that has been made towards addressing the international AML/CFT standards. It is noted that two countries have not issued regulations under the core legislation, but have published guidelines. One country only has draft subordinate legislation and has not yet published guidelines.