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Aml cft check

Skill Zerif007/Claude_Legal-Bangladesh_Edition/bd-regulatory-compliance/skills/aml-cft-check

AML/CFT compliance review under the Money Laundering Prevention Act 2012, Anti-Terrorism Act 2009, MLP Rules 2019 and BFIU circulars. Use for "AML check", "are we a reporting entity", KYC/CDD program review, STR/CTR questions, sanctions screening, or when a bank/ regulator raises AML queries.From its SKILL.md

Install
npx -y skills add Zerif007/Claude_Legal-Bangladesh_Edition --skill aml-cft-check

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SKILL.md

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AML/CFT Check — MLPA 2012 / BFIU

Config gate + criminal-exposure protocol: anything suggesting an actual suspicious transaction, live investigation, or ACC/BFIU/CID contact → stop analysis, escalate to named senior counsel, preserve documents, remind about tipping-off prohibitions.

Review sequence

  1. Reporting-entity status per MLPA 2012 s.2 definitions (banks, FIs, insurers, money changers, capital-market intermediaries, DNFBPs — real estate, dealers in precious metals, lawyers/accountants in specified transactions, NGOs/NPOs). The DNFBP perimeter has been widening via circulars — [verify current BFIU circular set].
  2. If a reporting entity: program adequacy — CAMLCO appointment, board-approved policy, KYC/CDD (+ e-KYC per BFIU e-KYC guidelines), beneficial-ownership drill-down, PEP handling, transaction monitoring, STR (suspicious transaction) and CTR (cash transaction, threshold per current circular [verify]) reporting rails to BFIU, record retention (5 years+), training cadence, independent audit.
  3. Sanctions/CFT: AT Act 2009 UNSCR implementation — screening against UN lists per BFIU circulars; freeze mechanics.
  4. If not a reporting entity: counterparty/AML hygiene — bank onboarding expectations, agent-network risk, cash-intensity flags, trade-based ML exposure for import/export businesses (over/under-invoicing is the classic Bangladesh TBML fact pattern — customs-value discipline matters).
  5. Predicate-offence awareness: MLPA schedules a wide predicate list (corruption, tax offences, forgery...). Corporate exposure includes fines and licence consequences; individuals face imprisonment — set the tone accordingly.

Output: attorney-review draft — status determination, program gap table vs BFIU circular requirements (each row citing the circular [verify number/date]), remediation plan, escalation triggers, and a one-page board summary (sanitized, no privileged speculation).

What ships with it

Read from the repository

Just SKILL.md. No reference files, no scripts.

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