In general, what is an element that a financial institution or business does not have to specifically address in an anti-money laundering program?

Internationally recognized standards, such as those from the Financial Action Task Force (FATF), and national regulations mandate the core elements of an Anti-Money Laundering (AML) program. These foundational pillars are (A) a system of internal policies, procedures, and controls; (B) a designated compliance officer; and (C) an ongoing employee training program. An independent audit function is also a required pillar. While screening against government watch lists (like those from the Office of Foreign Assets Control - OFAC) is a critical compliance function and part of a robust system of internal controls, it is technically a distinct regulatory obligation from AML. A specific description of an OFAC program is not a universally required, standalone pillar of an AML program itself.

A. A system of internal policies, procedures and controls is a foundational pillar of any AML program, as required by FATF and national laws.
B. A designated compliance officer is a universally required element to ensure accountability and oversight of the AML program.
C. An ongoing employee training program is essential for ensuring staff can identify and report suspicious activity, a core AML requirement.

1. ACAMS CAMS6 Study Guide (6th Edition). Chapter 2, "Compliance Standards for Anti-Money Laundering and Combating the Financing of Terrorism," details the key elements of an AML/CFT program. It explicitly lists internal policies, procedures and controls; a designated compliance officer; ongoing training; and an independent audit function as the core components. Sanctions compliance is discussed as a related but separate risk area.

2. Financial Action Task Force (FATF). (2012-2023). International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation - The FATF Recommendations. Paris: FATF/OECD. Recommendation 18 and its Interpretive Note require financial institutions to have AML/CFT programs that include the development of internal policies, procedures and controls; a designated compliance management function; and an ongoing employee training program.

3. Bank Secrecy Act (BSA), 31 U.S.C. 5318(h)(1). As amended by the USA PATRIOT Act, this statute codifies the minimum requirements for an AML program in the United States, known as the "four pillars" (now five, with the addition of customer due diligence). These pillars are (1) internal controls, (2) a designated compliance officer, (3) ongoing employee training, and (4) an independent audit function. This demonstrates that options A, B, and C are legally mandated program elements.