Chapter V

Programme Governance & Controls

Translate obligations and risk appetite into ownership, controls, quality assurance, auditability and accountable programme governance.

01AML Governance & Three LinesAssign ownership across business, compliance oversight and independent assurance.02Quality Assurance & Audit ReadinessTest case quality, control effectiveness, evidence sufficiency and remediation.03Third-Party Reliance & OutsourcingManage reliance, outsourcing risk, vendor controls and accountability.04Data Protection & AML RecordkeepingRetain AML evidence while controlling privacy, access and purpose limitation.05Verification & Evidence ControlsTest whether evidence supports the decision, not just whether a file exists.06Role & Authority MatrixDefine analyst, reviewer, MLRO and governance authority boundaries.07Analyst Operating Workflow GovernanceDefine scope before account opening and route subjects to required checks.08Evidence Pack GovernanceStandardise case metadata, screening records, decisions, retention and audit trail.