AML/CFT policy manual drafting

A registered DNFBP needs a written AML/CFT policy manual describing how the business identifies, assesses, and manages money-laundering risk — not a generic template, but a document that reflects how your firm actually transacts. A typical policy manual we draft for a client covers:

• AML/CFT governance structure and MLRO responsibilities
• Customer due diligence and enhanced due diligence procedures
• Screening, monitoring, and escalation workflows
• Record-keeping standards and retention periods
• Suspicious activity reporting and internal escalation paths
• Staff training and annual review requirements

We don't publish sample policy manuals on this site — the content is specific to each client's risk profile and would be misleading as a generic example. A full outline of what a policy manual covers is available on request during a scoping call.

Annual review and gap-assessment audits

Policies age. Regulatory guidance shifts, business activities expand, and a manual written for a five-person brokerage doesn't necessarily still fit once the firm has grown or diversified. We run annual gap-assessment audits against current obligations and update the policy manual so it stays a document a regulator can rely on, not one that was accurate the year it was written.