Applicability - Anti Money Laundering / Countering Financing of Terrorism (AML/CFT)
Applicability
The AML/CFT requirements apply to all reporting institutions, and may be administratively developed by the accountants, company sectaries, lawyers and REAs at the firm level to ensure consistent application of AML/CFT requirements within the firm.
However, some responsibilities under the AML/CFT requirements, such as the submission of suspicious transaction report still rest with the individual reporting institution.
For accountants, company secretaries and lawyers, Part IV of the AMLA is only applicable to those carrying on Gazetted Activities as published in P.U.(A) 340/2004 and P.U.(A) 293/2006.
However, for lawyers, there could be circumstances of spill-over, in which the funds from litigation process may pass-through the client account, and hence form part of the Gazetted Activities.