In implementing the policies, procedures and monitoring tools for ensuring compliance with Paragraph FC-2.1.3, licensees should consider the following:

(a) The business policies and practices should be designed to reduce incentives for staff to expose the licensee to AML/CFT compliance risk;
(b) The performance measures of departments/divisions/units and personnel should include measures to address AML/CFT compliance obligations;
(c) AML/CFT compliance breaches and deficiencies should be attributed to the relevant departments/divisions/units and personnel within the organisation as appropriate;
(d) Remuneration and bonuses should be adjusted for AML/CFT compliance breaches and deficiencies; and
(e) Both quantitative measures and human judgement should play a role in determining any adjustments to the remuneration and bonuses resulting from the above.
Added: April 2020