Session 1: The Board’s Role and Regulatory Landscape

Objective: Strengthen the Board’s understanding of AML/CFT governance responsibilities and the regulatory expectations relevant to microfinance institutions.

Topics Covered:

1. The Board’s Role in AML/CFT Governance

• Legal and ethical responsibilities.
• Defining and approving the institution’s AML/CFT risk appetite.
• Oversight of compliance function structure and adequacy of resources.
• Promoting a compliance-oriented culture and tone from the top.

Regulatory and Legal Framework

• National AML/CFT laws and Central Bank instructions for microfinance institutions.
• International standards (FATF Recommendations, Basel principles).
• Supervisory expectations and the implications of non-compliance (regulatory, reputational, and operational).

Session 2: Understanding and Overseeing AML/CFT and Sanctions Risks

Objective: Enable the Board to effectively identify, assess, and oversee ML/TF and sanctions risks, ensuring robust program governance and accountability.

Topics Covered:
3. Understanding ML/TF Risks and Typologies

• Key ML/TF risks in the microfinance sector.
• Customer, product, and delivery channel risk factors.
• Sector-specific typologies and red flags.

4. Institutional Risk Assessment and AML Program Effectiveness

• Oversight of enterprise-wide AML/CFT risk assessments.
• Key risk indicators (KRIs) and performance indicators (KPIs).
• Evaluating AML program effectiveness and ensuring corrective measures.

Sanctions Compliance

• Overview of national and international sanctions regimes.
• Screening obligations for customers and transactions.
• Governance for handling matches, alerts, and escalation.
• The Board’s accountability in sanctions compliance oversight.

Session 3: Ethical Leadership, Technology Oversight, and Case Study Discussion

Objective: Reinforce ethical leadership, promote a strong compliance culture, and enhance the Board’s understanding of AML technology and data governance.

Topics Covered:
6. Compliance Culture and Ethical Leadership

• Setting the tone from the top and demonstrating ethical governance.
• Encouraging transparency and whistleblowing.
• Accountability and reinforcing integrity across the institution.

7. Technology and Data Analytics in AML/CFT

• Overview of AML technologies: monitoring, screening, case management.
• Role of automation, AI, and data analytics in enhancing compliance effectiveness.
• The Board’s role in overseeing technology adequacy, cybersecurity, and data privacy.

Case Study and Discussion

• Review of real-world AML/CFT or sanctions-related incidents.
• Lessons learned for Board-level oversight and governance improvement.
• Open discussion on strengthening institutional compliance posture.