Members Code of Conduct
Principle I: Responsibility to the Profession
Principle II: Responsibility for Professional Competence
The anti-money laundering practitioner is aware that trust in the profession depends upon a level of professional conduct and responsibility that may be higher than required by law. This entails holding one and other practitioners to the same ethical standards.
The anti-money laundering practitioner demonstrates responsibility to oneself as an ethical professional by:
Acknowledging that lack of awareness, knowledge, or understanding of the Code is not, in itself, a defense to a charge of unethical conduct;
Knowing and upholding the procedures, policies, laws and regulations relevant to professional practice regardless of personal views;
Holding oneself responsible for ethical conduct;
Monitoring and maintaining sound mental, physical, and emotional health necessary to perform duties and services of any professional assignment; and taking appropriate measures when personal or health-related issues may interfere with work-related duties;
Refraining from professional or personal activity that may lead to reducing one’s effectiveness within the AML practitioners community;
Avoiding the use of one’s position for personal gain and avoiding the appearance of impropriety; and
Taking responsibility and credit only for work actually performed or produced, and acknowledging the work and contributions made by others.
The anti-money laundering practitioner fulfills the obligation to address and attempt to resolve ethical issues by:
Confronting and taking reasonable steps to resolve conflicts between the Code and the implicit or explicit demands of a person or organization;
Maintaining fidelity to the Code by taking proactive steps when having reason to believe that another practitioner may be approaching or involved in an ethically compromising situation;
Neither discriminating nor retaliating against a person on the basis of having made an ethical complaint;
Neither filing nor encouraging frivolous ethical complaints solely to harm or retaliate; and
Cooperating fully during ethics investigations and proceedings
The anti-money laundering practitioners promotes and advances the profession within and beyond the AML practitioners community by:
Influencing and supporting decisions and actions that positively impact anti-money laundering compliance and professional conduct;
Engaging in respectful discourse regarding issues that impact the profession;
Enhancing one’s professional effectiveness by staying current with ethical principles and decisions from relevant sources including professional organizations;
Actively participating in educational and professional capacity building activities; and
Advocating for adequate resources and facilities to ensure equitable opportunities for all practitioners.
The anti-money laundering practitioner is committed to the highest levels of professional and ethical practice, including demonstration of the knowledge, skills and dispositions required for professional competence.
The anti-money laundering practitioner demonstrates commitment to high standards of practice through:
Incorporating into one’s practice global and national standards, including those specific to one’s discipline;
Using the Model Code of Practitioners Ethics and other ethics codes unique to one’s discipline to guide and frame practitioners decision-making;
Advocating for equitable educational opportunities for all practitioners;
Accepting the responsibilities, performing duties and providing services corresponding to the area of certification, licensure, and training of one’s position;
Reflecting upon and assessing one’s professional skills, content knowledge, and competency on an ongoing basis; and
Committing to ongoing professional learning.
The anti-money laundering practitioner demonstrates responsible use of data, materials, research and assessment by:
Appropriately recognizing others’ work by citing data or materials from published, unpublished, or electronic sources when disseminating information;
Using developmentally appropriate assessments for the purposes for which they are intended and for which they have been validated to guide decisions;
Conducting research in an ethical and responsible manner with appropriate permission and supervision;
Seeking and using evidence, instructional data, research, and professional knowledge to inform anti-money laundering practice;
Creating, maintaining, disseminating, storing, retaining and disposing of records and data relating to one’s research and practice, in accordance with national laws; and
Using data, data sources, or findings accurately and reliably.
The anti-money laundering practitioner acts in the best interest of all practitioners by:
Increasing members’ access to the organization, activities, and resources in order to provide a quality and equitable membership experience – by sharing updates/events.
Working to engage the AML practitioner’s community to close achievement, opportunity, and attainment gaps; and
Protecting practitioners from any practice that harms or has the potential to harm practitioners.
Principle III: Responsibility to Fellow Members
Principle IV: Responsibility to the Practitioner’s community
The anti-money laundering practitioners has a primary obligation to treat fellow members with dignity and respect. The anti-money laundering practitioner promotes the health, safety and wellbeing of members by establishing and maintaining appropriate verbal, physical, emotional and social boundaries.
The anti-money laundering practitioner respects the rights and dignity of fellow members by:
Respecting fellow members by taking into account their name, age, gender, culture, setting and socioeconomic context;
Interacting with fellow members with transparency and in appropriate settings;
Communicating with fellow members in a clear, respectful, and culturally sensitive manner;
Taking into account how appearance and dress can affect one’s interactions and relationships with fellow members;
Considering the implication of accepting gifts from or giving gifts to fellow practitioners;
Engaging in physical contact with fellow members only when there is a clearly defined purpose that benefits the member and continually keeps the safety and well-being of the member in mind;
The anti-money laundering practitioners demonstrates an ethic of care through:
Seeking to understand fellow members, educational, academic, personal and social needs as well as member’s values, beliefs, and cultural background;
Respecting the dignity, worth, and uniqueness of each individual members including, but not limited to, actual and perceived gender, gender expression, gender identity, civil status, family status, sexual orientation, religion, age, disability, race, ethnicity, socio-economic status, and culture; and
Establishing and maintaining an environment that promotes the emotional, intellectual, physical, and sexual safety of all members.
The anti-money laundering practitioners maintains fellow members trust and confidentiality when interacting with fellow member in a developmentally appropriate manner and within appropriate limits by:
Respecting the privacy of members and the need to hold in confidence certain forms of member communication, documents, or information obtained in the course of professional practice;
Upholding member’s legal rights, as well as any legal requirements to reveal information related to legitimate concerns for the well-being of a member; and
Protecting the confidentiality of member records and releasing personal data in accordance with prescribed national laws and local policies.
The anti-money laundering practitioners promotes positive relationships and effective interactions, with members of the AML practitioner’s community, while maintaining professional boundaries.
The anti-money laundering practitioners promotes effective and appropriate relationships with regulators and supervisors by:
Communicating with supervisors/regulator in a timely and respectful manner that represents their organizations best interests;
Demonstrating a commitment to equality, equity, and inclusion as well as respecting and accommodating diversity among members of the AML practitioner’s community;
Considering the implication of accepting gifts from or giving gifts to regulators/supervisors; and
Maintaining appropriate confidentiality with respect to organization information disclosed by or to regulator/supervisor unless required by law.
The anti-money laundering practitioners promotes effective and appropriate relationships with colleagues by:
Respecting colleagues as fellow professionals and maintaining civility when differences arise;
Resolving conflicts, whenever possible, privately and respectfully;
Keeping employers safety and confidentiality paramount by maintaining and sharing compliance records appropriately and objectively in accordance with national laws;
Collaborating with colleagues in a manner that supports academic achievement and related goals that promote the best interests of members;
Enhancing the professional growth and development of new practitioners by supporting effective field experiences, mentoring or induction activities across the career continuum;
Ensuring that practitioners who are assigned to participate as mentors for new practitioners, cooperating practitioners, or other organization leadership positions are prepared and supervised to assume these roles;
Ensuring that practitioners are assigned to positions in accordance with their educational credentials, preparation, and experience in order to maximize practitioner’s opportunities and achievement; and
Working to ensure a workplace environment that is free from harassment.
The anti-money laundering practitioners promotes effective and appropriate relationships with the community and other stakeholders by:
Advocating for policies and laws that the AML practitioner supports as promoting the AML Compliance and well-being of the organization and shareholders;
Collaborating with community agencies, organizations, and individuals in order to advance AML Compliance best interests without regard to personal reward or remuneration; and
Maintaining the highest professional standards of accuracy, honesty, and appropriate disclosure of information when representing their organization within the community and in public communications.
The anti-money laundering practitioners promotes effective and appropriate relationships with employers by:
Using property, facilities, materials, and resources in accordance with organization policies and national laws;
Respecting intellectual property ownership rights (e.g. AML Policies, training notes, STRs, LCT’s, annual returns, GoAML etc.) when sharing materials;
Exhibiting personal and professional conduct that is in the best interest of the organization, AML practitioner’s community, and profession; and
Considering the implications of offering or accepting gifts and/or preferential treatment by vendors or an individual in a position of professional influence or power.
Principle V: Responsible and Ethical Use of Technology
The anti-money laundering practitioners considers the impact of consuming, creating, distributing and communicating information through all technologies. The ethical anti-money laundering practitioner is vigilant to ensure appropriate boundaries of time, place and role are maintained when using electronic communication.
The anti-money laundering practitioners uses technology in a responsible manner by:
Using social media responsibly, transparently, and primarily for purposes of screening, ongoing monitoring and learning per organization policy. The anti-money laundering practitioners considers the ramifications of using social media and direct communication via technology on one’s interactions with staff, the regulator, and the general public;
Staying abreast of current trends and uses of anti-money laundering and communication technology;
Promoting the benefits of and clarifying the limitations of various appropriate technological applications with colleagues, appropriate staff, regulator, and community members;
Knowing how to access, document and use proprietary materials and understanding how to recognize and prevent tipping off by staff and educators;
Understanding and abiding by your organizations policy on the use of technology and communication;
Recognizing that some electronic communications are records under the Data Privacy and Protection Act (DPPA) and Anti-money Laundering Act (AMLA) laws and should consider the implications of sharing sensitive information electronically either via professional or personal devices/accounts; and
Exercising prudence in maintaining separate and professional virtual profiles, keeping personal and professional lives distinct.
The anti-money laundering practitioners ensures staff safety and well-being when using technology by:
Being vigilant in identifying, addressing and reporting (when appropriate and in accordance with organization policy and national legislation) inappropriate and illegal materials/images in electronic or other forms;
Respecting the privacy of staff presence on social media unless given consent to view such information or if there is a possibility of evidence of a risk of harm from the staff or others; and
Monitoring to the extent practical and appropriately reporting information concerning possible cyber bullying incidents and their potential impact on the staff working and learning environment.
The anti-money laundering practitioners maintains confidentiality in the use of technology by:
Taking appropriate and reasonable measures to maintain confidentiality of client information and transactional records stored or transmitted through the use of electronic or computer technology;
Understanding the intent of the Data Privacy and Protection Act 2019 (DPPA) and how it applies to sharing electronic customer records; and
Ensuring that the rights of third parties, including the right of privacy, are not violated via the use of technologies.
The anti-money laundering practitioners promotes the appropriate use of technology in compliance settings by:
Advocating for equal access to technology for all members of staff, especially;
Promoting the benefits of and clarifying the limitations of various appropriate technological applications with colleagues, appropriate staff personnel, regulators, and community members; and
Promoting technological applications (a) that are appropriate for staff’ individual needs, (b) that staff understand how to use and (c) that assist and enhance the screening and ongoing monitoring process.