Most AML laws and regulations require reporting entities to conduct a comprehensive ML/TF risk assessment and then design an AML Program that is proportionate to the ML/TF risks that have been identified.
The next step in this process is to create an AML Program Manual.
This step is optional and can be skipped if an AML Program Manual already exists in another format, such as Word or PDF.
Tip: That file can be uploaded to the Appendix.
2. Structure of the AML Program Manual
Getting started on developing the AML Program Manual could not be simpler.
Based on decades of experience and practical AML operational knowledge our experts have developed a template for the AML Program that covers a range of areas that AML regulators would typically expect to see, including:
- Introduction to the AML Program
- Roles and Responsibilities
- ML/TF Enterprise Risk Assessment
- Risk-based Systems and Controls
- Governance of the AML Program
- Customer Due Diligence Program
- Enhanced Customer Due Diligence
- Unacceptable Customers
- Ongoing Customer Due Diligence
- Transaction Monitoring Program
- AML Awareness Training
- Employee Due Diligence
- Record Keeping
- Tipping Off
- Regulator Feedback
- Independent Review or Audit
- Targeted Financial Sanctions
3. How it works
The AML Program Manual is laid out in the above standard sections but can be fully tailored and configured to suit the specific requirements of your organisations particular circumstances.
The AML Program describes under each section the typical information that should be included and the requisite level of detail and information that an AML regulator might typically expect to see when reviewing an AML Program.
After the AML Program Manual has been edited and the user has completed the review step then this can be published which automatically stores an online and PDF version of all the artefacts created during the process including the AML Program Manual
This has been designed to be a thought kick-starter, rather than something that can be adopted wholesale without any consideration of your organisations particular circumstances, so it is very important to read carefully and modify the template accordingly.
4. Editing Content
The AML Program Manual has an in-built rich text editor, similar to Microsoft Word, which allows you to fully control the text, for example, applying bold, colour, italic, headings, bullets, text location and tables etc.
Click on the item you want to edit (chapter/section heading, or description field), make the changes and click Save.
You will notice some text with yellow highlighting which contain suggestions, for example, frequency, ownership or other information. This is to draw the user's attention that this can be changed to the organisation's specific circumstances.
Note: Remember to remove the yellow highlight and square brackets when done.
5. Adding or Removing Content
In addition to the pre-defined contents that are fully editable, the AML Program Manual has the flexibility to allow new chapters and sections to be added to the document. Click the three dots (...) beside a chapter or section and then select Append Chapter or Add Section which will add a new blank chapter/section underneath.
It is also possible to remove unwanted chapters or sections by clicking the three dots (...) of the chapter/section to be removed, and then selecting Remove.
6. Re-ordering Content
The order in which the chapters and sections are displayed can be changed by clicking the Reorder button. Drag and drop the chapters and sections into the desired order and then click Save, or Save and Exit to return to the main AML Program Manual edit page.