AML / CFT Programme Minimum Expectations | Circular

AML / CFT Programme Minimum Expectations

Circular setting out minimum expectations for Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) controls across operators and suppliers.

Circular No: NLA/AML/01/2025 Category: Financial Crime Status: Active

1. Overview

This circular defines baseline AML / CFT expectations. Applicants must demonstrate not only policies, but actual monitoring, escalation, and control ownership.

2. Core Principle

If your AML programme only exists as a document and not as an operational workflow, it will not pass scrutiny.

3. Minimum Control Areas

Control Area Expectation
Customer Due Diligence Identity verification, risk classification, and onboarding controls
Ongoing Monitoring Transaction monitoring with defined alert triggers
Escalation Clear internal escalation pathway for suspicious activity
Recordkeeping Retention of logs, alerts, and investigation outcomes
Reporting Defined process for reporting suspicious activity where required

4. Operational Expectations

5. Evidence Requirements

6. Common Failures

7. Supporting Resources

8. Contact

For clarification:

Marketing & Communications
info@nevesgaminglicense.org
General Enquiries

9. Effective Date

This circular takes effect immediately upon publication.