© The Author(s), under exclusive license to APress Media, LLC, part of Springer Nature 2023
K. SullivanAnti-Money Laundering in a Nutshellhttps://doi.org/10.1007/979-8-8688-0066-5_5

5. Building a Quality AML Program for Financial Institutions

Kevin Sullivan1  
(1)
Flowery Branch, GA, USA
 
Recommended Elements of a Quality AML Program
The Five Pillars
Internal Policies and Procedures
Designated Compliance Officer
Independent Audit Function
Training
Customer Due Diligence
Risk Management
Conducting Due Diligence
Customer Risk
Product and Service Risk
Geographic Risk
Ultimate Beneficial Ownership
Common Program Deficiencies
Summary
The anti-money laundering (AML) universe basically consists of three entities that attempt to fight the good fight against the bad guys: ...

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