Aml Cft

AML / CFT (Counter-Terrorist & Proliferation Financing)

When to Use

• Assess terrorist financing (TF) typologies and red flags distinct from general money laundering
• Design or improve CFT/PF controls, policies, and risk appetite—not a full AML program from scratch
• Scope proliferation financing (PF) and dual-use goods exposure in trade finance or correspondent flows
• Map targeted financial sanctions (TFS), designation lists, and asset freeze operational workflows (conceptual)
• Draft CFT-specific STR/SAR narrative structure and internal escalation fact packs (not filing legal advice)
• Conduct charitable NPO and nonprofit sector due diligence and de-risking decisions
• Evaluate MVTS (money/value transfer services), remittance corridors, and informal value transfer risks
• Address correspondent banking and cross-border TF vulnerabilities and nested-account risks
• Align controls to FATF Recommendations 6–8 and related interpretive guidance at a high level
• Integrate sanctions screening with CFT disposition, true-match escalation, and freeze holds
• Plan CFT training, independent review, and exam readiness for TF/PF-focused questions

When NOT to Use

• Build or mature a full risk-based AML program (KYC tiers, CDD/EDD, TM scenarios, MLRO governance) → aml-compliance
• Implement SOC 2, ISO 27001, or technical control evidence automation only → compliance-engineer
• Internal/IT audit workpapers without CFT/PF or sanctions lens → auditor
• Legal advice, regulatory interpretation as counsel, contract redlines, or filing strategy → commercial-counsel
• Deploy SIEM, screening software engineering, or IAM (primary) → information-security-engineer
• Sanctions API/oracle integration only → chainalysis-sanctions-screening (pointer), then route CFT context here
• Law enforcement investigation tactics, attribution, or victim tracing → blockint / on-chain-investigator-agent skills
• General money laundering typologies without TF/PF angle → aml-compliance

Related skills

Core Workflows

1. CFT/PF risk scoping

1. Inventory products, channels, and geographies with TF/PF exposure (NPO, MVTS, trade finance, crypto, correspondent)
2. Document inherent CFT/PF risk separately from general AML inherent risk where useful
3. Map controls to FATF R6–R8 themes (TFS, PF, NPO) at a high level
4. Prioritize gaps with owners, evidence, and trigger-based refresh (new corridor, designation, exam finding)

See references/aml_cft_scope.md.

2. Typology-led detection and monitoring

1. Select TF typologies relevant to the business model (self-funding, front NPO, MVTS, trade-based TF)
2. Translate typologies into red flags, scenarios, and analyst investigation playbooks
3. Separate CFT alerts from general AML and fraud where systems differ
4. Tune with documented approvals; track false positives and missed-pattern feedback

See references/terrorist_financing_typologies.md and references/npo_mvts_and_cross_border_cft.md.

3. PF, dual-use, and trade exposure

1. Identify customers, corridors, and commodities with proliferation or dual-use sensitivity
2. Apply PF red flags (opaque ownership, shell intermediaries, inconsistent shipping docs)
3. Coordinate with trade finance and sanctions teams on holds and escalations

See references/proliferation_financing_and_dual_use.md.

4. TFS, screening, and asset freeze

1. Run sanctions and TFS screening with match disposition and audit trail
2. On true match or designation: initiate freeze workflow, block movements, restrict account access (per policy)
3. Document reporting to competent authority where required—escalate legal/compliance for timing and content
4. Manage delisting, unfreeze, and license/Exception pathways only with counsel guidance

See references/targeted_sanctions_and_asset_freeze.md.

5. Reporting, governance, and exam readiness

1. Assemble CFT-focused STR/SAR fact packs: TF purpose indicators, networks, channels, NPO links
2. Maintain need-to-know, confidentiality, and record retention per policy
3. Prepare CFT/PF exam samples: TFS policies, NPO procedures, MVTS oversight, training logs, independent review

See references/reporting_governance_and_exam_readiness.md.

When to load references

Operating principles

• Typology-first — anchor controls and investigations to known TF/PF patterns, not only ML rules
• Separate TF from ML — document why activity suggests terrorist or proliferation purpose
• No legal conclusions — provide fact packs and draft structures; MLRO/counsel decide filings and freezes
• Sanctions are immediate — treat TFS hits as priority; do not process pending legal comfort informally
• NPO nuance — apply risk-based approach; avoid blanket de-risking without governance
• Label uncertainty — screening and open-source intel are heuristic; document confidence and gaps