Model policy · version 1
AML Program
Stand up the written program the sponsor bank relies on: a named officer with real authority, trained staff, an independent test on the calendar, and a board that sees the numbers every quarter. This is the document an examiner reads first and the frame every other AML policy hangs from.
What’s in this policy11 sections · AML Program · Read the full policy
9Obligations · things you must do
19Evidence · records that prove it
1Monitoring · checks and deadlines
1Reporting · reports you must send
Does this apply to you?
Answer a few questions and each obligation is marked applies, likely, or needs more information.
Tell Leela about your companyHand over the whole policy
Every obligation in this policy, in one request.
What the policy requires
Automate
Leela can perform the work through your connected systems.
Monitor
Leela can watch for the trigger, keep the clock, and flag what is late.
Prepare for review
Leela can prepare the artifact and hand it to a person for review.
Human required
A person must do the work; Leela can track it and file the evidence.
TriggerEvent-driven · At program launch, and on any change of officer; written notice to the sponsor bank on each change
EvidenceOfficer designation, Sponsor bank notice
TriggerAnnual · Approved at adoption; re-approved after each annual review or material change
EvidenceApproved policy, Board minutes
TriggerAnnual · Within 30 days of each start date; annual refresher; role modules on assignment
EvidenceTraining completion log, Training content
TriggerAnnual · First test within six months of launch; annually thereafter
EvidenceEngagement letter, Test report, Remediation log
TriggerQuarterly · Board report within 30 days of quarter close; sponsor bank report on the agreed cadence
EvidenceBoard compliance report, Sponsor bank compliance report
TriggerAnnual · Each year on the policy anniversary, or earlier on a material change; bank notice on each material change
EvidenceAnnual review record, Material change notice
TriggerEvent-driven · Each unresolved alert, each potential match, and each request, within the timeframe the procedure or the bank sets
EvidenceEscalation and coordination log, Bank correspondence
TriggerContinuous · Channel open at all times; each report acted on when received
EvidenceViolation report log, Staff acknowledgment
TriggerContinuous · Five years from the date of each record
EvidenceRetention schedule entry, Program document archive