Board of directors' approval of a bank's own internal policies and procedures to address money laundering and terrorist financing is critical if a bank wishes to be seen to be fully committed to its appreciation of, and willingness to, mitigate money laundering and terrorist financing risks in its daily banking operations.

The Centre therefore expects that the internal anti-money laundering and terrorist financing policies and procedures of a bank should be adopted and approved by the board of directors of that bank.

This will also ensure that the board of a particular bank takes ownership of its obligations in terms of the FIC Act. The criminal penalties for failure to comply with the obligations under the FIC Act are severe, and directors may be held personally liable. Forbearance in prosecuting criminal matters under the FIC Act must not be expected.