Report program performance to the board quarterly and to the sponsor bank

AML Program policy, §7.4, §8.3

The AML Compliance Officer delivers a compliance report to the board, or its designated committee, at least quarterly and within 30 days of quarter close, covering program performance, material issues, test findings and remediation status, training completion, regulatory developments, and open items with the sponsor bank. The board reviews the report, acts on the material issues it raises, and its review is minuted. The Company also provides the sponsor bank with periodic compliance reports carrying the program metrics the bank specifies, on the cadence and in the format agreed at launch and no less than quarterly.

Quarterly

Board report within 30 days of quarter close; sponsor bank report on the agreed cadence

Pull the quarter’s metrics, draft the board package and the bank report, deliver each before its deadline, and file the minutes and the bank’s receipt.

• Board compliance report

  Quarterly package with the date delivered and the minutes of the review

• Sponsor bank compliance report

  Metrics report in the agreed format, with the date sent

AML Compliance Officer

Leela can assemble the quarter’s metrics into the board package and the bank report for the officer to finish and sign.

Tell Leela about your company to see whether this applies.