Issue: № 5, 2025
Doi: https://doi.org/10.37634/efp.2025.5.21
It is shown that a banking institution is obliged to ensure an appropriate AML/CFT risk management system based on a risk-based approach; proportionality of procedures and measures to the nature and scale of the bank's activities; continuity of internal control and documentation of all decisions related to AML/CFT. It is established that combating money laundering protects a bank's reputation, reduces regulatory risks, and increases customer trust. At the same time, transparency of financial transactions contributes to building an effective customer strategy and offering profitable financial solutions. Mandatory requirements for the content of internal banking documents in the field of AML/CFT are described: the presence of risk-oriented procedures; determination of the procedure for organizing and operating AML/CFT and PFM systems; regulation of approaches to ML/CFT risk management; description of monitoring, detection, response and escalation processes. The principles of development and implementation of internal documents of the bank on AML/CFT issues, which are based on a risk-based approach, documentation of the processes of its application, are substantiated. It is shown that all internal documents on AML/CFT issues should be based on the principles of proportionality, reasonableness and demonstrability of the bank's actions when making decisions on business relationships and financial transactions. They should contain mandatory details and provisions, identify responsible units and employees in terms of establishing authority and responsibility for implementing AML/CFT procedures, and distributing responsibilities between structural units. The following elements of the AML/CFT management system in the bank are proposed: identification of key client categories, risk criteria and indicators of suspicious transactions, formalization of signs of risky behavior; prompt response to risk signals; formation of an electronic client questionnaire; correspondent relations with foreign financial institutions. Mechanisms for combating money laundering have been developed (transaction monitoring system, collection and verification of customer data, reporting to government agencies, staff training), as well as mechanisms for increasing the profitability of bank customers (providing personalized financial products, investment services, digital platforms and mobile banking, introducing loyalty and cashback programs, teaching financial literacy).
Keywords : financial mechanisms, banks, clients, money laundering, countering legalization, increasing profitability, business entities
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