Commission an independent test of the program every year
The program is tested at least annually by a qualified firm independent of the program’s operation, with the first test scoped and engaged within six months of program launch. The scope covers the five pillars, the program controls, and the sponsor bank’s requirements. Each finding is assigned an owner and a target date, remediation is tracked to closure, and the report and remediation status go to the board and the sponsor bank.
Annual
First test within six months of launch; annually thereafter
Engage the firm, agree the scope, provide the records, log each finding with an owner and date, track remediation to closure, and deliver the report to the board and the bank.
- Engagement letter
Signed, with the scope and the firm’s independence stated
- Test report
Final report with findings and management responses
- Remediation log
Per finding: owner, target date, closure evidence
AML Compliance Officer
A person must do the work; Leela can track it and file the evidence.
Leela can keep the testing calendar, hold the remediation log, and flag findings past their target date.
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.