Internal Policies and Procedures

These shape how an FI operates overall, not specifically tied to “customer phases.”

Require dual authorizations and segregated duties for high-risk transactions to ensure that no single employee can bypass or override AML controls. This structure directly mitigates bribery by limiting the potential impact of any single compromised or coerced insider.

Enforce rigorous cash-handling rules, such as mandating ID verification for buy-ins over specified limits and requiring manager approval for multiple near-threshold transactions. Prohibit or strictly control third-party chip purchases and ensure documented oversight of any suspicious group activity in cages and gaming areas. These measures are aimed at deterring structured transactions by mule networks.

Institutionalize multi-level approval protocols, segregation of duties, and explicit accountability for editing transaction data. Mandate clear checks and authorizations before implementing any high-risk modifications, limiting the ability to perform unobserved or unauthorized document changes.

Restrict the acceptance or issuance of bearer shares or bonds within a financial institution’s policies, particularly those from high-risk jurisdictions. Require that existing bearer instruments be converted to registered (nominative) form, where possible, as a condition of doing business.

Establish strict internal protocols requiring staff to flag frequent deposit box visits, recurring large cash payments for box rental, and requests for multiple or unusually large boxes without plausible justification. Mandate senior management or compliance approval for high-risk deposit box rentals and ensure each box access is logged with a verified ID check. These procedures directly mitigate unchecked anonymity and repetitive suspicious usage of safe deposit boxes.

Establish standardized procedures for cross-border trade transactions, requiring thorough verification of shipping documents, invoice consistency, and legitimacy of multi-jurisdiction counterparties. By embedding these checks into daily operations and mandating additional sign-offs for large or high-risk trade remittances, institutions can detect and prevent fictitious or inflated invoices used to launder funds across multiple jurisdictions.

Establish and enforce conflict-of-interest policies, role segregation, and thorough escalation protocols for syndicated trade loans. Require explicit staff disclosures and dual authorizations for high-value or unusual financing requests, ensuring that any questionable contract terms receive heightened scrutiny and reducing the possibility of insider collusion.

Implement structured procurement guidelines that require independent reviews, mandatory price comparisons, and random audits of bidding processes. Ensure there are multiple sign-off requirements so that no single individual can manipulate contract awards.

Institute clear currency-handling protocols that require staff to use counterfeit-detection tools on all cash deposits above a defined threshold or in cases of suspicious presentation. Mandate immediate segregation and documentation of suspected fake notes, along with a non-retaliation policy for employees who raise concerns. By standardizing these procedures, institutions address the risk of inconsistent counterfeit screening and overcome staff reluctance to confront customers who might present bogus cash.

Adopt rigorous change management protocols that require dual controls and clear documentation for any financial record alterations. Define strict processes for reviewing and approving edits, supported by disciplinary measures for unauthorized modifications. By enforcing structured governance, institutions deter casual tampering and maintain accountability for all record changes.

Implement strict governance frameworks mandating dual authorization for major transactions, segregated oversight of compliance changes, and board-level sign-off on critical AML policy revisions. Dividing authority in this manner makes it significantly more difficult for illicit actors to override safeguards once they infiltrate high-level positions.

Institute mandatory dual authorization for changes to monitoring thresholds or security configurations, with documented approval workflows and segregation of duties. By clearly assigning responsibility for system administration and enforcement, institutions limit opportunities for a single insider to covertly reconfigure AML controls to conceal illicit flows.

Implement rigorous expense reimbursement controls requiring itemized receipts, mandatory managerial approvals above specific cost thresholds, and standardized expense forms. Schedule random spot checks and enforce dual sign-off for high-value claims. By ensuring each reimbursement is validated with complete documentation and oversight, institutions reduce opportunities for forged receipts and inflated expenses, directly targeting expense report fraud vulnerabilities.

Enforce mandatory out-of-band verification for any changes in vendor payment instructions or contact details, requiring staff to confirm alterations through verified phone calls or in-person channels. Cross-check new information against existing vendor records before finalizing payments to intercept fraudulent requests.