AML Program
AP-06Review the policy annually and notify the bank of material changes
How Leela would run itAnnual · each year on the policy anniversary, or earlier on a material change; bank notice on each material change
From the policy libraryThe requirement
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.
- 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
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.
What Leela keepsThe evidence this obligation leaves, as the work happens
Listed from the policy libraryContents
- 01Annual review recordDate, reviewer, changes considered, changes made
- 02Material change noticeNotice to the sponsor bank with the date sent
Evidence
Annual review record
AML Program §8.2, §4.2
2
of 2 records
The work and the records come from this obligation in the policy library.