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What are the 5 Pillars of AML Compliance that One Should Consider? Implementation of Effective Internal Controls.Designation of a Compliance (AML) Officer.Appropriate Periodic TrainingForEmployees.Independent Testing of the Program.Customer Due Diligence.
The key 5 pillars of an AML Program are internal controls, a designated BSA officer, ongoing training, independent testing, and customer due diligence (CDD) the newest pillar.
The basic components of a BSA/AML compliance program include: Risk Assessment. Internal Controls Review. Independent Testing (Audit) BSA/AML Compliance Officer. BSA/AML Compliance Training.
Currently, institutional AML programs are based on the five pillars: internal policies, procedures and controls; designation of an AML officer; employee training; independent testing; and customer due diligence (CDD).
FINRA provides a template for small firms to assist them in fulfilling their responsibilities to establish the Anti-Money Laundering (AML) compliance program required by the Bank Secrecy Act (BSA) and its implementing regulations and FINRA Rule 3310.
How many risk assessments are needed for a BSA Program? The core procedures in the Manual identify three key risk assessments: Anti-Money Laundering (AML) Risk Assessment, CIP Risk Assessment, and OFAC Risk Assessment.
The elements include the detection of suspicious activity, risk assessment, internal practices, AML training and independent audits.
The written BSA/AML compliance program must include the following four pillars: Internal controls; The designation of a BSA/AML officer; A BSA/AML training program; and. Independent testing to test programs.
For many years AML compliance programs were built on the four internationally known pillars: development of internal policies, procedures and controls, designation of a AML (BSA) officer responsible for the program, relevant training of employees and independent testing.
There are usually two or three phases to the laundering: Placement. Layering. Integration / Extraction.