1. Financial institutions' programmes against money laundering and terrorist financing should include:

(a) the development of internal policies, procedures and controls, including appropriate compliance management arrangements, and adequate screening procedures to ensure high standards when hiring employees;

(b) an ongoing employee training programme; and

(c) an independent audit function to test the system.

2. The type and extent of measures to be taken should be appropriate having regard to the risk of money laundering and terrorist financing and the size of the business.

3. Compliance management arrangements should include the appointment of a compliance officer at the management level.