Governance + training + independent testing: VASPs must establish appropriate governance arrangements for Travel Rule compliance including: (a) BOARD + SENIOR MANAGEMENT OVERSIGHT - the Travel Rule programme must be approved by the board + reviewed periodically + reported on; (b) DEDICATED COMPLIANCE FUNCTION - a designated compliance officer + AML/CFT officer with Travel Rule responsibilities + adequate resources + authority; (c) WRITTEN POLICIES + PROCEDURES - the Travel Rule policy must be written + approved + reviewed; (d) ANNUAL TRAINING for all employees with Travel Rule responsibilities + role-specific training for high-volume / complex roles; (e) INDEPENDENT TESTING - the Travel Rule programme must be tested by an independent function (typically internal audit OR external audit) at least annually + the test results reported to management + the board; (f) ISSUE TRACKING + REMEDIATION - identified deficiencies must be tracked + remediated + remediation effectiveness verified. The 2024 Targeted Update reinforced that governance + independent testing are MUTUAL EVALUATION priority areas + non-compliance is increasingly cited in supervisory enforcement.
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