Review the policy annually and notify the bank of material changes

AML Program policy, §8.2, §4.2

This policy is reviewed at least annually and updated for changes in the product suite or business model, changes in the sponsor bank agreement or its compliance requirements, regulatory developments, findings from the independent test or quality assurance, and examination guidance for program managers. The AML Compliance Officer follows BSA/AML regulatory developments so the review has what it needs, approves material changes, and gives the sponsor bank notice of each material change under the change management protocols in the program agreement.

Annual

Each year on the policy anniversary, or earlier on a material change; bank notice on each material change

Gather the year’s product, bank, regulatory, and testing changes, revise the policy, approve it, notify the bank of what changed materially, and put it to the board.

• Annual review record

  Date, reviewer, changes considered, changes made

• Material change notice

  Notice to the sponsor bank with the date sent

AML Compliance Officer

Leela can draft the annual review from the year’s changes and findings and keep the anniversary clock.

Tell Leela about your company to see whether this applies.