What is an AML compliance program? It is the documented and operational system a regulated firm uses to identify, assess, manage, and mitigate money laundering, terrorism financing, and proliferation financing risk. A strong program includes governance, risk assessment, CDD, EDD, reporting, training, record keeping, and review.
This article is general information and is not legal advice.
What an AML compliance program includes
An AML compliance program should describe what the firm must do and how staff should do it. The program should be specific to the firm's customers, services, jurisdictions, delivery channels, products, and risk profile.
Program area | Practical purpose
Governance | Defines responsibility, oversight, and approval.
Risk assessment | Identifies ML/TF risks in the business.
Policies and procedures | Sets the rules staff must follow.
CDD and EDD | Explains how customers are identified, verified, risk rated, and reviewed.
Reporting | Defines suspicious matter and other reporting paths.
Training | Ensures staff understand the program and internal process.
Records | Preserves evidence, decisions, and review history.
Review | Tests whether the program still works.
Program document vs operating workflow
The document is only part of the program. The operating workflow is what staff use every day. A written rule that says "conduct customer due diligence" is weak unless staff know which documents to request, when to escalate, who approves exceptions, and how to keep records.
This is where software can help. Workflow software turns the program into intake forms, evidence requests, risk scoring, review queues, approval steps, monitoring triggers, and audit trails.
How Veraxa supports AML programs
Veraxa helps firms convert AML compliance program requirements into controlled workflows. Continue with AML/CTF program software, AML compliance software, and the Tranche 2 AML requirements checklist.
Frequently asked questions
What is an AML compliance program?
It is the firm's system for managing AML risk through governance, risk assessment, CDD, EDD, reporting, training, records, and review.
What does an AML compliance program consist of?
It usually consists of governance, risk assessment, policies, procedures, customer due diligence, enhanced due diligence, reporting, training, record keeping, and review.
Is a policy document enough?
No. The firm also needs operational workflows that staff can follow and records that prove controls were applied.