Templates are useful, but they are not the same as AML/CTF readiness. For PNG reporting entities, the board question is not simply whether a policy exists. The better question is whether the organisation can show that the policy matches its risk profile, is understood by the people using it, and can be evidenced when BPNG, FASU, auditors or counterparties ask.
Questions boards should ask
- Does the AML/CTF programme reflect our actual products, customers, channels, geography and delivery partners?
- Can management explain the highest ML/TF risks without reading from a template?
- Are customer due diligence, enhanced due diligence and ongoing monitoring steps practical for front-line teams?
- Is there a clear owner for implementation, exceptions, escalation and board reporting?
- Can we produce evidence: training records, risk decisions, customer files, screening outcomes, incident handling and review logs?
- What would fail first if a regulator, bank, correspondent, auditor or board committee tested this tomorrow?
What readiness looks like
Readiness means the documentation, controls, people and evidence line up. A strong pack should include the AML/CTF programme, ML/TF risk assessment, CDD/KYC forms, compliance officer and board reporting material, implementation plan and review cadence. The work should be right-sized for PNG conditions and usable by the team that has to operate it.
How Kyudo helps
Kyudo helps PNG organisations move from documentation to implementation readiness. Our ABLE approach aligns the risk and board intent, builds practical tools, helps teams learn the operating rhythm, and enables capability transfer. We succeed when you do not need us.
