The AML Policy Framework
What Top-Performing Institutions Do Differently
The AML Policy Framework That Sets You Apart
Structure That Works
4-Tier Documentation Framework
Tier 1: Board Policies
Tier 2: Management Policies
Tier 3: Operational Procedures
Tier 4: Job Aids & Quick References
Each tier provides the appropriate detail for the intended audience.
The W’s Test
What Makes Procedures Actionable
WHO performs each task?
WHAT specific actions are taken?
WHEN do activities occur?
HOW is completion evidenced?
Be specific. Avoid vague terms.
Keys to Excellence
What Sets Leaders Apart
▸ Tailored and risk-based, not generic templates
▸ Documentation matches actual practices
▸ Adequately resourced BSA functions
▸ Customized monitoring systems
▸ Strong board oversight
Keep it Current
Update Triggers
▸ New products, services, or customers
▸ Regulatory changes or guidance
▸ Merger, acquisitions, or IT changes
▸ Examination findings
▸ Minimum: Annual risk assessment review
The Excellence Mindset
What Regulators Value Most
▸ Policies that are effective, not just comprehensive
▸ Implementation that is aligned with documentation
▸ Risk-based = tailored to your institutions
▸ Continuous improvement, not annual checkbox
▸ Prevent ML/TF while managing compliance expectations
Your Action Plan
Next Steps towards Excellence
1. Conduct comprehensive Risk Assessment
2. Tailor all policies to YOUR risk profile
3. Write specific, actionable procedures
4. Ensure adequate board oversight
5. Test for implementation, not just documentation
