Section 11: Internal control measures

(1) An accountable person shall develop, adopt and implement internal control measures, policies and procedures for the prevention of money laundering and financing of terrorism. (2) For the purposes of subregulation (1), the measures shall include- (a) monitoring systems for complex, unusual or large transactions or suspicious activities; (b) enhanced due diligence procedures with respect to persons and business relations and transactions carrying high risk; (c) monitoring systems for persons in jurisdictions that do not have adequate systems to combat money laundering or terrorism financing; (d) training programmes for the purposes of continuous training of employees, managers and directors of the accountable person, so as keep those persons up to date in all aspects of anti-money laundering and combating of terrorism financing requirements including any new developments, methods and trends concerning due diligence measures and suspicious transactions reporting systems; (e) awareness programmes for the purposes of ensuring that employees, managers and directors of the accountable person are sufficiently knowledgeable about- (i) the procedures relating to combating of terrorism and terrorism financing; (ii) the provisions of the Act and these Regulations; (iii) any policies, directives, codes or guidelines issued by the accountable person relating to anti-money laundering and combating of terrorism financing; (f) maintenance of a manual to facilitate compliance with procedures, processes and working methods relating to antimoney laundering under the Act or these Regulations; (g) systems relating to carrying out of independent audits to review and verify compliance with and effectiveness of the measures taken in accordance with the Act and these Regulations; (h) mechanisms for the sharing of information obtained by an accountable person with other accountable persons including systems that ensure the confidentiality of the shared information. Anonymous or fictitious accounts