Anti-Money Laundering ("AML") Audit
This is an essential toolkit to guide you through your internal AML Audit, to prepare
you for the independent outside AML audit. A well-run AML Compliance Program is a
requirement under the USA PATRIOT Act (2001) and your obligations under FinCEN and FINRA
rules. This is a must-have for the AML Compliance Officer.
The Audit Checklist is divided into four discreet parts:
- Part I looks at the Policy itself.
- Part II looks at actual practice. Therefore, while information may seem redundant in
these parts, it is being reviewed at a different level.
- Part III looks randomly at actual accounts that have been opened and looks at the
account opening process and trading.
- Part IV notes inconsistencies in policy versus practice, general comments, and
Also included is a user-friendly AML Policy template. This, and all the forms are
delivered in WORD for your easy customization. The Information Sheet will help you sort
through the regulatory maze and the mound of forms (SARs, CTRs, CIMR, FBAR, and other
FinCEN and OFAC forms).
The AML Audit Package includes:
- AML Audit Checklist
- AML Policy Template (contains enhancements from the FINRA template)
- AML Customer Notice
- AML Special Measures
- AML Information Sheet