AML Compliance Program

What this video covers

• The five core components of a written anti-money laundering (AML) program, and how to spot the fake sixth requirement the exam often sneaks in
• The exact responsibilities of the AML compliance officer (AMLCO), and why running the program day-to-day does not require senior management status
• The independent testing schedule: annual for most firms, then the specific two-year exception for firms that do not carry customer accounts or execute customer transactions
• What "independent" actually means in independent testing: separation from program administration, not necessarily an outside party
• The four Customer Identification Program (CIP) data points required for every new account, and why existing customers opening additional accounts get no pass
• The chronological AML sequence from CIP through ongoing monitoring to Financial Crimes Enforcement Network (FinCEN) reporting
• The USA PATRIOT Act as the mandate behind CIP, and how to distinguish CIP front-door identity verification from ongoing customer due diligence surveillance