Policy template · 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
Commission an independent test of the program every year
Specialist-led
Review the policy annually and notify the bank of material changes
Prepare for review