The TRACFIN correspondent serves as the interface with the financial intelligence unit. They receive acknowledgements of reports, process right-of-communication requests, and disseminate vigilance alerts. This function is essential for maintaining effective communication with TRACFIN and responding promptly to information requests.

The AML/CFT framework officer is responsible for supervising the operational deployment of the framework, developing and updating the risk map, and defining AML/CFT policies and procedures. They must also regularly inform governance bodies and, for groups, coordinate with central functions. This role is crucial for ensuring effective management of money laundering and terrorist financing risks.

Internal audit's primary role is to conduct periodic reviews of the AML/CFT system to verify its compliance with regulatory requirements and its effectiveness. It reports its findings to the audit committee and governance bodies. This role is crucial for ensuring the independence and objectivity of framework evaluations.

The first line of defence consists of the operational teams in direct contact with clients, such as advisors and account managers. Their role is crucial because they are responsible for detecting anomalies and escalating alerts without making a definitive judgement. This underscores the importance of training these staff, who represent the first barrier against money laundering.

Under Article R.561-23 of the CMF, the TRACFIN reporting officer function may under no circumstances be outsourced, even in smaller organisations. This function must be performed internally to ensure the confidentiality and integrity of suspicious transaction reports. This underscores the importance of internal independence and responsibility in AML/CFT risk management.

Under Articles R.561-23 and R.561-24 of the CMF, it is possible for these two roles to be performed by the same person in smaller organisations. However, they may under no circumstances be outsourced. This flexibility allows smaller organisations to adapt their resources while complying with regulatory obligations.

The KYC (Know Your Customer) process is a crucial process governing the establishment of a business relationship. It includes client identification, identity verification, screening against sanctions lists and politically exposed persons, and the collection of information on the purpose and nature of the business relationship. This process results in the assignment of a risk profile and a decision to accept or refuse the client.

The KYC process and ongoing monitoring are two distinct but complementary processes. KYC focuses on the onboarding of the client, while ongoing monitoring concerns the monitoring of transactions throughout the relationship. Distinguishing between these two processes is essential for effective risk management.