Can an institution choose not to make their internal AML guidelines available for anyone to see?
It is not necessary for banks to submit detailed AML guidelines as they can submit a summarised version of their guidelines provided the summary is reasonably detailed and would allow confirmation that adequate policies and procedures are in place. Banks can also fill out the Wolfsberg Group Anti-Money Laundering Questionnaire on Bankersalmanac.com. Alternatively they can supply a statement confirming that they are compliant with relevant law as set out by regulatory/governing bodies of the country and this will appear against their entry on the Repository.
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- Can an institution choose not to make their internal AML guidelines available for anyone to see?
