AML/CFT Policy Package
Complete AML/CFT policy kit for banks, MFOs, payment organizations and fintech companies.
What it is and why you need it
These are not just templates — this is a ready-made internal compliance system for a company required to comply with AML/CFT requirements under Uzbekistan law. The regulator (CBU, Markaz) looks specifically at the existence and quality of these documents during inspections. Without them: a directive, a fine, licence suspension.
What happens without proper policies
- Regulatory directive following an inspection
- Licence suspension or revocation
- Personal liability of the compliance officer
- Fines for each identified breach of KYC procedures
- International correspondent banks refuse to cooperate
- Payment system transaction blocking
What's included
| 1. AML/CFT Policy | Core document. Risk management system, roles and responsibilities, suspicious transaction detection procedures, STR submission to Markaz |
| 2. KYC Policy | Identification procedures for individuals and legal entities, risk levels, Enhanced Due Diligence for high-risk clients |
| 3. KYB Policy | Counterparty and business partner verification, beneficial ownership analysis, sanctions list screening |
| 4. Merchant Due Diligence Policy | Merchant onboarding and monitoring procedure, MCC categories, high-risk business indicators |
| 5. Employee Training Programme | AML/CFT training structure: initial briefing, annual training, testing, completion log. Ready for regulatory submission |
Who it's for
| Who | How they use it |
|---|---|
| Payment systems (Payme, Click, Uzum and similar) | Required under CBU licence |
| MFOs and credit organisations | Regulatory requirement |
| Exchange offices and forex brokers | Licence condition |
| Crypto and digital asset platforms | Markaz requirements 2023–2024 |
| Marketplaces with payment functionality | Growing payment compliance requirements |
| Law firms and auditors | DNFBP — required to have their own AML policies |
Why this is a system, not a template
Companies pay lawyers $500–$2000 to develop these documents from scratch. Our package was developed by a practising AML Head with experience at the largest financial organisations in Central Asia. Delivery includes files and an adaptation guide for your company.
Frequently Asked Questions
Who is required to have an AML/CFT policy?
Banks, MFOs, PSPs, e-money issuers, insurance companies, and fintech entities.
What are the penalties for lacking AML/CFT policy?
Regulatory fines, corrective orders, license suspension or revocation.
How often should the policy be updated?
At least annually and upon legislative changes.