Regulatory Alerts2023-11-16
Circular 100-4 on Measures Banks Must Take to Implement Their Anti-Money Laundering, Counter-Terrorist Financing, and Counter-Proliferation Programs
The Bank of the Republic of Haiti issued Circular 100-4 to mandate that banks implement comprehensive anti-money laundering, counter-terrorist financing, and counter-proliferation programs in accordance with the April 30, 2023 decree. The circular requires banks to establish written policies, risk assessments, compliance officer appointments, internal controls, independent testing, and employee training tailored to their specific risk profiles. It further stipulates that non-compliance may result in administrative sanctions ranging from warnings to license revocation, with the circular entering into force on August 14, 2023.
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