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
  • 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 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 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 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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