For the person who has to sign, AML policy template is a phrase that gets searched by two people: the one who wants a definition for a memo and the one who has to sign an attestation about it next quarter. This page is written for the second. For a financial business under anti-money-laundering rules, AML policy template comes down to a record and a set of figures: the record is the customer due diligence, the transaction monitoring alerts, the suspicious activity reports and the training, kept with an owner, a date and a status; the figures are the evidence load that record puts on its reviewers, the days an audit of it takes, the gaps an audit will find and what they cost, the incidents and cases it produces, and the training it requires. The sections below explain AML policy template in those terms, say what it is not, and show where the free sheets on this site work each figure from the program's own numbers with no account.
What AML policy template means in practice
For a financial business under anti-money-laundering rules, it means being able to show, for each obligation, which control satisfies it, what evidence proves the control operated, who reviewed the evidence and who attested to the result. The record is the customer due diligence, the transaction monitoring alerts, the suspicious activity reports and the training. The regulator's own material, linked below, says what the obligations are; this site publishes none of that and no legal advice. What it publishes is the arithmetic: the obligations register sheet turns the count of obligations, controls and evidence items into reviewer hours and the months to a full attestation.
What the rule asks a program to contain
A written program, reasonably designed to prevent the business being used to launder money, with policies and procedures, a designated compliance officer, ongoing training for appropriate personnel, and an independent review to monitor and maintain it. That is the shape the rule sets out, and a template can give you the headings for all five and the content of none. The part that is invented rather than copied is the risk assessment the policies are supposed to follow from, because it has to describe your products, customers and geographies rather than somebody else's.
Why the search is AML policy template
The words in AML policy template are the words a financial business under anti-money-laundering rules uses when the obligation has a name and the program does not yet have a number. The name is the regulator's, linked below; the number is the program's own, and it is the count of obligations, controls and evidence items behind AML turned into reviewer hours on the obligations register sheet and into audit days on the audit scope sheet. A program that searches AML policy template and comes away with those two figures has done the first day of the work, and the paid plan on this site keeps what follows: the record, with owners, dates and the attestation that closes each period.
What AML policy template is not
It is not a certificate, a piece of software or a consultant's memo, although all three are sold under the name. It is a record and the figures that follow from it, kept by the business that owes the obligations. The guide this page supports covers scoping regulatory compliance consulting from the register, the help a small business buys around that record. Attestvio Pro keeps the record at one flat price; the sheets are free with no account.
The figures behind AML policy template
Evidence items and reviewer hours; audit samples, days and coverage; expected gaps, remediation hours and cost; incident hours; case backlog months; training seats outstanding. Each is a free sheet on this site and each computes from the program's own inputs. For AML the sheet to start with is the case aging sheet, which works the figure a financial business under anti-money-laundering rules is examined on first. A program that knows those numbers has stopped estimating its own compliance.
Questions people ask about AML policy template
What is AML policy template?
For a financial business under anti-money-laundering rules: keeping the customer due diligence, the transaction monitoring alerts, the suspicious activity reports and the training as a record with an owner, a date and a status, and being able to show for each obligation the control, the evidence and the attestation. The regulator's own material, linked below, defines the obligations; the free sheets on this site work the arithmetic.
Who is responsible for AML policy template in a small business?
The compliance officer, or the owner wearing that hat, who signs the attestation. The sheets on this site are written for that person and need no account.
Does Attestvio make a business compliant with AML?
No. The business meets the obligations; Attestvio keeps the record and works the figures, and publishes no rule and no advice. Counsel and the regulator's own material say what the obligations are.