The role of the TBAML Management Committee is to ensure that the organization’s TBAML program is effective, efficient, and compliant with applicable laws and regulations. TBAML Committee is a senior management level committee headed by the organization’s Chief Executive Officer or CEO to look after trade-related issues and matters, including money laundering and terrorist financing risks. TBAML Committee’s secretary is the trade-based money laundering reporting officer or TBMLRO.
TBAML Committee shall enhance the trade-based compliance oversight role in the areas of ML/TF risks associated with trade transactions. In this respect, Committee shall institute clear policies and procedures defining the responsibilities of the board of directors and TBAML Committees.
The Role of the TBAML Management Committee
The TBAML Committee performs the following broader roles:
Development and implementation of Trade Customer Risk Profiling Framework and Transaction Monitoring System for managing ML/TF risks
Implementation of technology-based trade solutions
Periodic review of distinct risk profiles and trade compliance issues and non-compliances
Review of trade reports, which provide useful insight into the internal controls, to gauge their adequacy to mitigate trade-related ML/TF risks
Development and implementation of “trade products price verification policy,” including the level of acceptable price variance
Ensuring regular trade compliance-related training sessions are provided to trade department officers engaged in processing trade business to enhance their skill set for dealing with ML/TF risks emanating from trade transactions
Final Thoughts
The TBAML (Trade-Based Money Laundering) Management Committee is responsible for overseeing and managing the implementation of TBAML policies, procedures, and controls within a financial institution or organization. The committee is typically composed of senior executives and key stakeholders from various departments within the organization, such as compliance, risk management, and legal. Overall, the TBAML Management Committee plays a critical role in managing and mitigating TBAML risks within an organization, and in ensuring that the organization is compliant with applicable laws and regulations.
