What are the four pillars of AML

What is an AML Compliance Program?

To combat financial crime, banks, credit unions, and a host of other financial institutions around the world must develop and implement anti-money laundering (AML) compliance programs.

A financial institution's anti-money laundering strategy should be part of its broader compliance system and be designed to meet the requirements of its legal environment. However, given the complexity of AML laws, developing an effective AML program can be challenging. Anti-money laundering compliance is an ongoing process: the United States Bank Secrecy Act (BSA) was amended by a number of later laws (including the USA Patriot Act), while the EU launched its Fourth Anti-Money Laundering Directive in 2017 Introduced money laundering.

With that in mind, all financial institutions should have a deep understanding of what an AML compliance program must do and how to create a program that works for them.

What is the point of an AML compliance program?

In practice, an AML compliance program should ensure that an institution is able to detect and report suspicious activities related to money laundering, including tax evasion, fraud and terrorist financing, to the appropriate authorities. An AML compliance program should focus not only on the effectiveness of internal systems and controls used to detect money laundering, but also on the risk posed by the activities of clients and clients with whom an institution does business.

An AML program should be built on a solid foundation of regulatory understanding and overseen by employees who are experienced and competent enough to create a climate of compliance at all levels of their organization.

Establishing an AML program

When developing an AML compliance program, it is the responsibility of senior management to create a set of policies and procedures that are tailored to the unique needs of their company. While a variety of factors can affect the size and shape of your program, it should be based on a number of key criteria.


Risk assessment is a pillar of AML compliance and is a critical first step in building an effective program. No two institutions face the same AML risks, and your program should include factors such as the products and services you offer, your customers and Take clients and their geographic location into account.

Your approach to AML risk management should match the specific needs of your business - ideally, your AML program avoids the administrative burden of overconformity and the potential legal exposure of underconformity. There is no one-size-fits-all solution to the inherent challenges of the financial landscape; the individual institutions are expected to develop a solution that corresponds to their risk profile.

Internal controls

An AML compliance program should focus on the internal controls and systems the institution uses to detect and report financial crime. The program should include regular reviews of these controls to measure their effectiveness in maintaining compliance standards.

Internal AML controls extend to an institution's staff who should be aware of their own roles and responsibilities within the system, how to exercise due diligence on business interests, and how to manage policies and procedures that ensure compliance on an ongoing basis.

Independent audits

An effective AML compliance program should be integrated into a schedule for independent testing and audits by third parties. Independent testing should be mandated every 12-18 months, although institutions working in particularly high-risk areas might consider a more frequent schedule. The third party company selected to test AML compliance must be qualified to conduct a risk-based audit that is appropriate for your institution. In large institutes, this audit can be carried out by an internal team that is independent of AML and compliance.

AML training

While every employee of a financial institution should have adequate knowledge of the AML process, certain employees have greater responsibility for the implementation of the compliance program. It can make sense for an institution to introduce a basic level of training for all employees and to add further, targeted training to those with more AML-specific responsibilities. Therefore, an AML compliance program, similar to creating an audit and inspection plan, should ensure that these employees receive regular training and know how to perform their assigned tasks.

A variety of companies offer AML compliance training for employees who need to update their knowledge and skills.

Compliance Officer

AML programs should appoint a Chief Compliance Officer designate who is responsible for overseeing the overall implementation of the AML policy in their institute. AML compliance officers should have sufficient experience and authority in their institution to ensure that they can perform their duties effectively. These tasks include communicating with authorities and auditors, briefing senior management, and making AML policy recommendations based on audits and reports.

It goes without saying that AML compliance officers should be experts in the legal requirements of their local area: In the United States, AML compliance is heavily focused on the Bank Secrecy Act, so compliance programs can be managed by a "BSA Officer." " be monitored. In the UK, AML activities are also overseen by the Money Laundering Reporting Officer (MLRO), who reports to the National Crime Agency. In any event, the expertise of an AML compliance officer should extend not only to the regulatory process, but also to the financial crime details and methods that are entrusted to them for detection and reporting.


Would you like to learn more about our AML compliance solutions?