AML Program
AP-04Commission 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 libraryThe 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 libraryContents
- 01Engagement letterSigned, with the scope and the firm’s independence stated
- 02Test reportFinal report with findings and management responses
- 03Remediation logPer 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.