Get started
AML Program
AP-04

Commission an independent test of the program every year

How Leela would run itAnnual · first test within six months of launch; annually thereafter
From the policy library
The requirement
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.
Applies
Tell Leela about your company to see whether this applies.
Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

The work

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.

What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy library
Contents
  1. 01
    Engagement letter
    Signed, with the scope and the firm’s independence stated
  2. 02
    Test report
    Final report with findings and management responses
  3. 03
    Remediation log
    Per finding: owner, target date, closure evidence
Evidence
Engagement letter
AML Program §3.4
3
of 3 records

The work and the records come from this obligation in the policy library.

What’s next?