Anti-Money Laundering & Counter-Terrorism Financing Program
Anti-money laundering (AML) is a term mainly used to describe the legal controls that require all banks operating in the country and other regulated entities to prevent and report money laundering activities to Samoa's Money Laundering Prevention Authority.
To meet international standards, the local Money Laundering Prevention Authority made substantial and vital changes to Samoa's Anti Money Laundering Act 2000, now referred to as The Money Laundering Prevention Act 2007 (MLPA).
The Money Laundering Prevention Act (MLPA) 2007, Money Laundering Prevention Regulation (MLPR) 2009, Money Laundering Prevention Guideline 2010, and the Counter Terrorism Act (CTA) 2014 make money laundering and terrorist financing a criminal offence.
Compliance with the legislation is vital to ensure Samoa's good reputation globally and to maintain the integrity of its local financial system. The National Bank of Samoa Limited has an important role to play in combating money laundering and terrorist financing. Its overall responsibility is ensuring that its products, services and assets are not used or implicated to be involved with money laundering and terrorist financing.
Why does nbs have this program?
Anti-Money Laundering and Counter-Terrorism Financing requires nbs to have an AML/CTF Program in place that is subject to oversight by the Executive management and the Board of Directors. The Program incorporates an AML/CTF Policy, which contains the key obligations that apply directly to its employees.
The primary purpose of the AML/CTF Program is identifying, mitigating and managing the risks nbs may reasonably face of its products, services and assets being involved in or facilitating money laundering or terrorism financing.
How does the program apply at nbs?
nbs' AML/CTF Program takes a risk- based approach and it applies to all aspects of the business (for the purposes of adopting and reporting on compliance with the Program).
Key obligations
The key areas of the Program that apply directly to employees require them to:
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follow business processes to identify and verify true identity of new customers
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be confident that customers they are dealing with are who they claim to be
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be alert to suspicious customer transactions, activities or behaviors
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ongoing monitoring of customers account activities
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complete all required anti-money laundering or counter terrorist financing training
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follow business processes for record retention
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promote the AML/CTF compliance culture in the business
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update the AML/CTF Program, policy and procedural manual to embed new or changing regulatory obligations applicable to the bank