Anti-Money Laundering (AML) Compliance Program Audit Checklist

This comprehensive anti-money laundering (aml) compliance program audit checklist ensures regulatory compliance with FinCEN, OCC, Federal Reserve, FDIC, 31 CFR Part 1020. Comprehensive AML compliance program audit for financial institutions covering BSA/AML policy, customer due diligence, transaction monitoring, SAR filing, OFAC screening, and FinCEN requirements per 31 CFR Part 1020 (Bank Secrecy Act) and FFIEC BSA/AML Examination Manual. AML failures result in multi-billion dollar regulatory p

  • Industry: Financial Services & Banking
  • Frequency: Monthly / Quarterly
  • Estimated Time: 60 minutes
  • Role: Compliance Officer / Branch Manager
  • Total Items: 21
  • Compliance: FinCEN, OCC, Federal Reserve, FDIC, 31 CFR Part 1020

BSA/AML Program Requirements

Verify core program requirements per 31 CFR 1020.210.

  • Is written BSA/AML compliance program in place covering all four pillars (policies, officer, training, independent testing)?
  • Has a qualified BSA/AML Compliance Officer been designated with adequate authority and resources?
  • Has BSA/AML program been approved by board of directors and reviewed annually?
  • Is current AML risk assessment documenting customer risk, product risk, and geographic risk on file?
  • Is independent BSA/AML audit completed annually by internal audit or qualified third party?
  • Is annual AML training completed by all applicable staff with attendance records maintained?

Customer Due Diligence (CDD) and KYC

Verify CDD compliance per FinCEN CDD Rule 31 CFR 1010.230.

  • Is Customer Identification Program (CIP) in place verifying customer identity at account opening per 31 CFR 1020.220?
  • Are beneficial owners (25%+ ownership) of legal entity customers identified and verified per FinCEN CDD Rule?
  • Are customers assigned risk ratings (low/medium/high) based on documented risk factors?
  • Are high-risk customers (PEPs, cash-intensive businesses, correspondent banks) subject to enhanced due diligence?
  • Are customer risk ratings reviewed periodically and updated when triggering events occur?

Transaction Monitoring and Alert Investigation

Verify transaction monitoring per FFIEC examination requirements.

  • Is automated transaction monitoring system (TMS) in place covering all transaction types per AML risk profile?
  • Are all TMS alerts dispositioned within defined SLA with documented rationale?
  • Are TMS scenarios validated and tuned at least annually per model risk management requirements?
  • Are Currency Transaction Reports (CTRs) filed within 15 days for cash transactions exceeding $10,000 per 31 CFR 1010.311?
  • Is structuring detection in place and employees trained to identify and report customers breaking up transactions?

SAR Filing and OFAC Screening

Verify SAR and OFAC compliance.

  • Are written SAR decision procedures in place ensuring consistent filing decisions per FinCEN guidance?
  • Are SARs filed within 30 days of initial detection (60 days if no suspect identified) per 31 CFR 1020.320?
  • Are SAR records retained for 5 years per 31 CFR 1010.430 and SAR confidentiality maintained?
  • Is OFAC screening performed against SDN List at account opening, wire transfers, and ongoing monitoring?
  • Are OFAC hits investigated and accounts blocked/frozen with FinCEN notification per OFAC requirements?

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Why Use This Anti-Money Laundering (AML) Compliance Program Audit Checklist?

This anti-money laundering (aml) compliance program audit checklist helps financial services & banking teams maintain compliance and operational excellence. Designed for compliance officer / branch manager professionals, this checklist covers 21 critical inspection points across 4 sections. Recommended frequency: monthly / quarterly.

Ensures compliance with FinCEN, OCC, Federal Reserve, FDIC, 31 CFR Part 1020, FATF. Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What does the Anti-Money Laundering (AML) Compliance Program Audit Checklist cover?

This checklist covers 21 inspection items across 4 sections: BSA/AML Program Requirements, Customer Due Diligence (CDD) and KYC, Transaction Monitoring and Alert Investigation, SAR Filing and OFAC Screening. It is designed for financial services & banking operations and compliance.

How often should this checklist be completed?

This checklist should be completed monthly / quarterly. Each completion takes approximately 60 minutes.

Who should use this Anti-Money Laundering (AML) Compliance Program Audit Checklist?

This checklist is designed for Compliance Officer / Branch Manager professionals in the financial services & banking industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

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