AML Compliance Checklist

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Implemented a Customer Identification Program (CIP) Implemented Customer Due Diligence (CDD) procedures Enhanced Due Diligence (EDD) for high-risk customers Screened customers against OFAC and sanctions lists Implemented a risk-based AML compliance program Designated a BSA/AML Compliance Officer Established an independent testing/audit function Implemented ongoing monitoring and transaction surveillance Filed Suspicious Activity Reports (SARs) when required Filed Currency Transaction Reports (CTRs) for transactions over $10,000 Maintained required AML records for at least 5 years Provided ongoing AML training to all relevant employees Implemented procedures for correspondent banking due diligence Reviewed and updated the AML program annually Established procedures for beneficial ownership identification

AML Compliance Checklist

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