Maintain a board-approved written program covering the five pillars
The Company maintains a written AML program with the five elements the rule requires: internal policies, procedures, and controls; a designated AML Compliance Officer; ongoing employee training; independent testing; and risk-based customer due diligence. The board and the chief executive hold ultimate responsibility for the program. The board approves this policy at adoption and re-approves it after each annual review or material change.
Annual
Approved at adoption; re-approved after each annual review or material change
Keep this policy and its supporting documents current against the five pillars, put the policy to the board for approval, and record the approval in the minutes.
- Approved policy
Current version with the approval date and approver
- Board minutes
Resolution approving the policy, with date
AML Compliance Officer
A person must do the work; Leela can track it and file the evidence.
Leela can keep the pillar map current and flag when the approved version is older than the last material change.
Tell Leela about your company to see whether this applies.
Tell Leela how you handle it today, or hand it over: see what’s next.