AML/CTF governance bodies have an ongoing duty to analyse monitoring results, regulatory findings and emerging risks, feed those lessons back into policies, controls and training, and then repeat the cycle. This continuous “feedback loop management” best captures the committee’s recurring responsibility; individual tasks such as a periodic risk assessment sit within, but do not define, that loop.

A. Risk assessments are periodic, not the overarching continuous governance cycle.

B. Voluntary self-disclosures occur only when needed, not as a standing duty.

C. Maintaining lists is an operational task, not a board-level recurring responsibility.

1. Basel Committee on Banking Supervision, Sound management of risks related to money laundering and financing of terrorism (June 2016), paras 29-31.

2. ACAMS “Risk Management for AML/CTF Professionals” Study Guide (2020) Ch. 4, pp. 52-53.