Detection, deterrence, and money laundering prevention require the following on every AML checklist for banks:
1. AML requires an anti money laundering compliance officer (OCC) to oversee the entire application process, including the screening and issuance of business licenses.
2. AML requires periodic on-site audits of financial transactions by an AML compliance officer and a KBS officer.
3. AML requires notification by the office of the comptroller of the currency (OCC) to the designated senior management and key personnel of all negative findings in the on-site or off-site examinations.
In short, the primary responsibility of an anti money laundering compliance officer is to monitor compliance with the various provisions of the money laundering risk management act (MLRMA). The OCC and KBS have additional responsibilities, however. The AML officer or KBS and their designated senior management will conduct an on-site examination of financial activities. On the other hand, the OCC and KBS will have responsibility for determining if entities need to further enhance the AML compliance program with specific, applicable regulatory documents, such as the comprehensive loss underwriting exchange (CLUE) and the security rule list (SRL). They will also have responsibility for addressing customer concerns, issues, and suggestions on areas for improvement.
If senior management is unaware of the specific regulatory documents and requirements, they need to ensure that they do not assist in a money laundering or terrorist organization. Anti money laundering compliance officers should be very proactive in their efforts to ensure that senior management and all key personnel are very well informed about their respective firms' specific requirements and regulations. Failure to be well informed could prove costly to the firm. Unless specifically trained to do so by their bank, anti-money laundering officers should never provide any bank documentation to anyone.
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