Obligations Overview
Reporting Entities have legal obligations to implement controls that prevent, detect, and report money laundering, terrorism financing, and other serious financial crimes.
Below is a practical summary of the minimum obligations expected under Vanuatu’s AML&CTF framework.
Registration & Governance
- Register as a Reporting Entity (where required).
- Appoint an AML&CTF Compliance Officer.
- Ensure management oversight and accountability.
Customer Due Diligence
- Identify and verify customers and beneficial owners.
- Understand purpose and nature of business relationships.
- Apply enhanced measures for higher-risk customers.
Monitoring & Reporting
- Monitor transactions and customer activity.
- Report suspicious transactions promptly.
- Maintain internal controls and escalation processes.
Core Obligations
Minimum compliance expectations for Reporting Entities.
1) Register and maintain accurate details
Keep entity profile information up-to-date and ensure the right persons are authorised to act.
2) Appoint an AML&CTF Compliance Officer
Assign responsibility for day-to-day AML&CTF implementation, reporting, and liaison with FIU.
3) Conduct Customer Due Diligence (CDD)
Verify identity, beneficial ownership, and apply appropriate measures based on customer risk.
4) Apply ongoing monitoring
Monitor transactions and customer behaviour, and identify unusual or suspicious patterns.
5) Keep records
Maintain transaction records and CDD information for the required period, and ensure retrieval when requested.
6) Submit reports when required
Submit required reports accurately and on time, including suspicious transaction reporting where applicable.
7) Maintain policies, procedures, and training
Implement written procedures, risk controls, and staff training to ensure consistent compliance.
Compliance Cycle
- Identify ML/TF risks relevant to your business
- Implement controls and procedures
- Train staff and keep evidence
- Monitor customers and transactions
- Report suspicious activity and required information
- Review and improve controls regularly
Important
Failure to meet AML&CTF obligations may result in supervisory action, directions, penalties,
or other enforcement measures under the applicable legal framework.
Ensure your internal controls are practical, documented, and actively used (not only written).
Need Assistance?
If you need guidance on obligations, reporting, or compliance implementation, please contact the FIU.
Use the official contact channels listed on this website.