Which statement describes the minimum requirements for an AML program at a financial institution?

Which statement describes the minimum requirements for an AML program at a financial institution?

• A. A single compliance officer, no training, no audit
• B. AML program including policies and procedures, a designated compliance officer, employee training, and an independent audit function
• C. Only customer due diligence
• D. Only annual risk assessment

Answer: (B)

The minimum AML program must establish governance and ongoing oversight with written policies and procedures, a designated compliance officer responsible for AML, ongoing employee training, and an independent audit function to test effectiveness. This combination ensures clear accountability, helps staff recognize and report suspicious activity, and provides objective, regular verification that the program is working as intended. A lone compliance officer without training or an audit lacks oversight and validation. Focusing only on customer due diligence or only on an annual risk assessment misses the broader, ongoing controls and monitoring required for a robust AML program.

The minimum AML program must establish governance and ongoing oversight with written policies and procedures, a designated compliance officer responsible for AML, ongoing employee training, and an independent audit function to test effectiveness. This combination ensures clear accountability, helps staff recognize and report suspicious activity, and provides objective, regular verification that the program is working as intended. A lone compliance officer without training or an audit lacks oversight and validation. Focusing only on customer due diligence or only on an annual risk assessment misses the broader, ongoing controls and monitoring required for a robust AML program.