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Key Components of an AML Compliance Program

In order to deal with the evolving challenge of financial crimes, financial institutions across the globe are in dire need of developing methods that help them adopt and implement anti-money laundering (AML) practices.


In order to deal with the evolving challenge of financial crimes, financial institutions across the globe are in dire need of developing methods that help them adopt and implement anti-money laundering (AML) practices. They must demonstrate compliance with various regulatory bodies in order to play a significant role in the anti-money laundering journey.

It can be challenging to get financial institutions' business procedures in line with the necessary anti-money laundering/countering the financing of terrorism (AML/CFT) regulations and best practices. When the business is big and complex, the difficulty tends to increase.

Recent occurrences have demonstrated to us that financial institutions that break the law and regulations risk severe fines as well as harm to their reputation. The need for an AML program to be effective is more important than ever; simply having one is not enough. A well-implemented, successful program can also show an organization's stakeholders and employees that it is still committed to conducting business in an ethical and sustainable manner.

What is an AML compliance program?

Banks, fintechs, and other financial institutions around the world are required to develop and implement Anti-Money Laundering (AML) compliance programs in order to combat financial crime.

An anti-money laundering program is a set of rules and procedures that financial institutions must adhere to in order to prevent and detect money laundering or terrorist financing. The Bank Secrecy Act (BSA) of the United States has been amended by a variety of subsequent legislation (including the USA Patriot Act), while the EU introduced its Fourth Anti-Money Laundering Directive in 2017, and its Fifth Anti-Money Laundering Directive in 2020.

If you missed it, check out our article on how to build a comprehensive AML policy.

With this in mind, all financial institutions should have a solid grasp on what an AML compliance program should accomplish and how to design one that works for them.

What Is the purpose of an AML compliance program?

In practice, an AML compliance program should ensure that an institution can detect and report suspicious money-laundering activities such as tax evasion, fraud, and terrorist financing to the appropriate authorities. An AML compliance program should place emphasis not only on the effectiveness of internal money laundering detection systems and controls, but also on the risk posed by the activities of customers and clients with whom an institution does business.

An AML program should be built on a solid foundation of regulatory understanding and overseen by personnel who are experienced and knowledgeable enough to encourage a compliance culture at all levels of an organization.

Staying compliant

All AML compliance programs are meant to expose financial fraud, money laundering, tax evasion, terrorist financing, and a variety of other financial crimes. These objectives can be met by completing three important must-dos.

  • Credible reporting: a credible reporting system makes it easier to inform the appropriate authorities right off the bat about money laundering activity.
  • Keeping an eye out for high-risk customers: financial institutions must assess the profiles of their customers and handle them appropriately using measures like customer due diligence and enhanced due diligence in order to identify risky profiles and act to fix issues as soon as possible.
  • The team has a compliance officer: for this whole process to go smoothly and efficiently, it needs to be managed by a compliance officer. This is a person with the right experience who knows the operational limits of business compliance and the relevant needs.

    Compliance is a moral responsibility that must be managed well by all team members at all organizational levels. Employees must know how to spot and report anything that seems suspicious.

Key components of an AML compliance program

Financial institutions need to understand the key components of an AML compliance program so that they can prevent various types of financial fraud, which can have severe consequences. They need to adjust their policy guidelines, strategy, internal operations, and monitoring processes to comply with the given rules and regulations of an AML compliance program.

These key components can help cover the major areas of an AML compliance program so an organization stays within the regulatory framework, avoiding any legal issues.

Detection of Suspicious Activities

The initial objective is to quickly reveal actions connected to money laundering, such as:

  • Unusually large sums of money deposited on an account;
  • Insufficient amount of information submitted to open a bank account
  • False information submitted on the application

According to the FATF recommendation, if a financial institution has reason to believe that certain funds were obtained illegally or are associated with fraud and terrorism, it should promptly report these suspicions to a financial intelligence unit (FIU).

Comprehensive Policies and Procedures

Written policies and procedures that cover the full range of AML compliance issues are essential. Financial institutions need a solid, written foundation for every component of the program. Relationship managers, branch managers, and other financial sales representatives should have access to the policies and procedures.

Risk assessments

Money laundering and terrorist financing activity assessments can provide relative scores and categorize risky customers into various threat levels based on their individual credentials. High-risk countries, politically exposed persons (PEPs), due diligence reports, and ultimate beneficial owners (UBOs), are other factors to consider in this regard. The due diligence process is determined by the relevant AML jurisdictions.

Internal practices

An AML compliance program should place emphasis on the institution's internal practices and systems for detecting and reporting financial crime. The program should include regular reviews of those practices to assess their effectiveness in meeting compliance standards.

Employees of financial institutions should also be aware of their own roles and responsibilities within the system, how to conduct due diligence on business interests, and how to navigate policies and procedures that ensure ongoing compliance.

Know Your Customer (KYC) program

Customer risk assessments should be implemented during the onboarding process and re-evaluated whenever new, relevant information is learned, a customer expands into a new high-risk area, negative media is discovered, etc. A KYC program is an important first step in gathering data, focusing on the types of products and services; the expected pattern of activity in terms of transaction types, dollar volumes, and transaction frequency; the geographic location of the business and financial activity; and the status of high-risk individuals.

Carrying out independent audits

AML compliance programs that are effective should include a schedule of independent testing and auditing by third-party organizations. Independent testing should be mandated every 12-18 months, with institutions working in particularly high-risk areas considering a more frequent schedule.

The third-party organization selected to test the AML compliance program must be qualified to conduct a risk-based audit specific to your institution. In large institutions, this audit may be performed by an internal team separate from AML and Compliance.

Continuous monitoring and testing

When it comes to monitoring and auditing their compliance programs, financial institutions should become more adaptable. An AML compliance program generates a large amount of data and provides more than enough metrics to measure compliance. Trends must be updated on a regular basis. Annual independent evaluations and testing should be performed, and the report delivered directly to the CEO, senior management, and the Audit Committee.

AML training

While every employee within a financial institution should have a working knowledge of the AML process, specific employees will bear greater responsibility for the implementation of the AML compliance program. It may be appropriate for a company to implement a base level of training for all employees and then add additional, targeted training for those with more AML-specific responsibilities. As a result, in the same way that audit and testing schedules are created, an AML compliance program should ensure that those employees receive regular training and understand how to perform their assigned duties.

In conclusion

An AML/CFT compliance program not only assists financial institutions in complying with regulations but can also aid in spotting opportunities or potential weaknesses along the business process that may or may not be AML/CFT related. It also enables a compliance officer to better guide and advise internal stakeholders on ML/TF risks, as well as promote a culture that will benefit the organization in the long run.

Some may view such a program as a barrier to business efficiency or a financial cost to the organization, but failing to plan for regulatory compliance costs even more.

Find out how our solutions at Flagright use real-time financial crime insight to stay in control of AML compliance programs and keep pace with regulation.

Are you a fintech startup and applying for a fintech license? Flagright has you covered!

Contact us to schedule a free demo here.

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