What is an AML Compliance Program? (2024)

Risk & Compliance Glossary

What is an AML Compliance Program? (1)

What is an AML Compliance Program? (2)

An anti-money laundering (AML) compliance program helps businesses, including traditional financial institutions—as well as those entities identified in government regulations, such as money-service businesses and insurance companies—uncover suspicious activity associated with criminal acts, including money laundering and terrorist financing.

In the United States, the need for firms to have AML compliance programs stems from the Bank Secrecy Act (BSA). The Act established AML compliance program requirements, including that financial institutions adopt policies and procedures to detect suspicious activity and notify the government via the submission of Suspicious Activity Reports (SARs). The USA PATRIOT Act expanded the definition of an entity required to perform suspicious activity reporting.

In addition to uncovering money laundering and terrorism financing, the government uses SARs to pursue other forms of criminal activity, including fraud, bribery and corruption, tax evasion and organized crime.

Effective AML compliance programs

According to the Federal Financial Institutions Examination Council’s (FFIEC) (updated April 2020), a BSA/AML compliance program must include the following elements:

      • The existence of a system of internal controls to assure ongoing compliance
      • The performance of independent testing for compliance by bank personnel or by an outside party
      • Designation of a BSA compliance officer with responsibility for overseeing day-to-day compliance
      • Ongoing training for employees
      • A risk-based customer identification program (CIP) that allows an institution to establish the identity of its customers
      • Risk-based techniques for conducting ongoing customer due diligence (CDD) and complying with beneficial ownership requirements as detailed in regulations issued by Financial Crimes Enforcement Network (FinCEN)

Are all companies expected to maintain an AML program?

In the U.S., while companies not identified by the BSA or the USA PATRIOT Act need not create an AML program to ensure compliance, their activity may still trigger the submission of a SAR by their bank.

Learn more about financial crime regulatory compliance

What is an AML Compliance Program? (2024)

FAQs

What is an AML Compliance Program? ›

An anti-money laundering (AML) compliance program helps businesses, including traditional financial institutions—as well as those entities identified in government regulations, such as money-service businesses and insurance companies—uncover suspicious activity associated with criminal acts, including money laundering ...

What does AML program compliance officer do? ›

An AML Compliance officer is responsible for making sure an organization adheres to government or international regulations in the area of anti-money laundering by managing and overseeing day-to-day AML compliance and reporting to senior management on existing, new or emerging risks and controls to mitigate those risks ...

What is an example of AML compliance? ›

AML compliance programs must implement customer due diligence (CDD) rules to identify and assess each customer's risk of criminal activity. For example, FinCEN's CDD Rule requires financial institutions to: Identify and verify customer identities. Identify and verify beneficial owners' identities.

What are the five key elements of an AML program? ›

  • Pillar #1: appoint a compliance officer.
  • Pillar #2: complete risk assessments.
  • Pillar #3: prepare anti-money laundering policies and a procedure manual.
  • Pillar #4: monitor and maintain your AML program.
  • Pillar #5: implement customer due diligence.
Apr 27, 2023

What are the 4 ingredients of AML compliance? ›

The Four (4) Pillars Of BSA/AML Compliance
  • PILLAR #1. DESIGNATION OF A COMPLIANCE OFFICER.
  • PILLAR #2. DEVELOPMENT OF INTERNAL POLICIES, PROCEDURES AND CONTROLS.
  • PILLAR #3. ONGOING, RELEVANT TRAINING OF EMPLOYEES.
  • PILLAR #4. INDEPENDENT TESTING AND REVIEW.
  • CONCLUSION.
Mar 24, 2016

Is AML compliance a good career? ›

The AML field offers diverse and promising career opportunities. Professionals in these roles can expect competitive salaries and benefits, with opportunities to work in various sectors such as banking, financial services, and consulting firms.

What is required in an AML compliance program? ›

The program must include appropriate risk-based procedures for conducting ongoing customer due diligence, including (i) understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and, (ii) conducting ongoing monitoring to identify and report suspicious ...

What are red flags in AML compliance? ›

Other actions that are considered AML red flags in terms of suspicious transactions include large cash payments, unexplained third-party transactions, the use of multiple accounts, or the use of foreign bank accounts or virtual wallets, especially if they originate from diverse jurisdictions.

What is AML in simple words? ›

Anti Money Laundering (AML), also known as anti-money laundering, is the execution of transactions to eventually convert illegally obtained money into legal money. Although you as a company stick to the rules, this does not mean that your partners and business associates adhere to the same AML compliance laws as you.

Who needs AML compliance? ›

The AML/CTF Act currently regulates financial, gambling, remittance, digital currency exchange providers and bullion sectors that provide designated services listed in the AML/CTF Act.

What is an AML checklist? ›

This checklist summarises good practices in managing anti-money laundering (AML) compliance for firms and other organisations, including due diligence, risk assessment, policies and procedures and the role of the Money Laundering Reporting Officer (MLRO).

How to ensure AML compliance? ›

To help you incorporate the key components of an effective AML program, make sure you focus on these five elements:
  1. How to Detect Suspicious or Illegal Activities. ...
  2. Conducting Thorough & Regular Risk Assessments. ...
  3. Solidifying Your Internal Controls. ...
  4. Training. ...
  5. Third-Party Reviews From Independent Auditors.

What makes a good AML program? ›

Every AML program should have a compliance officer, resources dedicated to compliance, AML compliance policies, key controls and procedures, effective tools, and a strong compliance framework within an organization. An AML program should cater to the requirements and risks of an organization.

Who must comply with AML? ›

The BSA requires each bank to establish a BSA/AML compliance program. By statute, individuals, banks, and other financial institutions are subject to the BSA recordkeeping requirements.

Is AML risk or compliance? ›

AML compliance is a tangible process. You have to follow specific rules to comply with industry standards. If you follow these particular requirements of the AML regulator, you become AML-compliant. If you do not follow them, you will have to face penalties.

Is AML the same as compliance? ›

An anti-money laundering (AML) compliance program helps businesses, including traditional financial institutions—as well as those entities identified in government regulations, such as money-service businesses and insurance companies—uncover suspicious activity associated with criminal acts, including money laundering ...

What is the role of AML compliance function? ›

The AML compliance officer carries on the duties on behalf of the legal person or entity who provides all the required data to the legal person or entity, follows the procedures as per the AML laws, and helps prevent money laundering activities.

What are the tasks of AML officer? ›

Aml officer will oversee the creation, implementation, and ongoing oversight of their institution's anti-money laundering compliance program and manage the anti-money laundering compliance program inside their organization.

What are the duties of a compliance officer? ›

Compliance officers have a duty to their employer to work with management and staff to identify and manage regulatory risk. Their objective is to ensure that an organization has internal controls that adequately measure and manage the risks it faces.

What are your everyday responsibilities regarding AML compliance? ›

Everyday responsibilities regarding AML compliance include: Identifying money laundering risks. Executing risk assessments. Formulating and executing AML policies.

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