NIBAF AML & CFT study materials
NIBAF AML & CFT study resources

NIBAF AML & CFT: Compliance Programme Governance, Risk Assessment, Training and Record Keeping

NIBAF AML & CFT · Work through your exam, one topic at a time.

All guide sections

Compliance Programme Governance, Risk Assessment, Training and Record Keeping

Domain 8 covers governance, risk assessment, training and record keeping. The exam tests who owns the AML/CFT programme, how risk assessment drives controls, and what evidence an examiner expects.

Core rules

  • The board approves the AML/CFT policy and appetite; senior management implements it; the compliance function is independent and has access to the board.
  • The three lines of defence: business owns risk, compliance advises and monitors, internal audit provides independent assurance.
  • Enterprise-wide ML/TF risk assessment covers customers, products, channels, geography and delivery; customer risk rating must be applied consistently.
  • Training must be role-specific, documented and refreshed; board and senior management need appropriate training too.
  • Records must be sufficient to reconstruct transactions and demonstrate CDD for at least five years.

Worked example

A bank launches a digital wallet with agent cash-in. Before launch, it should complete a product risk assessment, set tiered CDD and limits, screen agents, configure monitoring for rapid pass-through, train staff and agents, and define record retention. Launching first and writing the policy later is a governance failure even if the app works.

Traps

  • Treating compliance as a single department rather than a three-lines model.
  • Running generic annual training with no role-specific content or testing.
  • Treating the risk assessment as a one-time document rather than a living control.
  • Keeping records for less than five years or failing to keep the rationale for decisions.