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What does an anti-money laundering compliance manual’s table of contents (TOC) look like?

An anti-money laundering (AML) compliance manual is a document that outlines the policies and procedures that an organization has in place to prevent, detect, and report money laundering activities. The table of contents of an AML compliance manual may vary depending on the size and complexity of the organization, but it generally includes the following sections:

  1. Introduction: This section provides an overview of the AML compliance program and explains the purpose of the manual.
  2. Scope: This section outlines the scope of the AML compliance program, including which business lines and geographies are covered.
  3. Legal and regulatory framework: This section describes the legal and regulatory requirements that the organization must comply with in relation to AML.
  4. Risk assessment: This section explains the process for conducting an AML risk assessment and identifying high-risk customers, products, and transactions.
  5. Customer due diligence: This section outlines the procedures for verifying the identity of customers and assessing their risk of money laundering.
  6. Suspicious activity monitoring and reporting: This section describes the process for detecting and reporting suspicious activity, including the use of transaction monitoring systems and the filing of Suspicious Activity Reports (SARs).
  7. Training and awareness: This section explains the training and awareness programs in place to educate employees on AML issues and their responsibilities.
  8. Record keeping: This section outlines the requirements for maintaining accurate and complete records related to AML compliance.
  9. Internal controls: This section describes the internal controls that are in place to ensure the effectiveness of the AML compliance program.
  10. Auditing and testing: This section explains the process for conducting internal and external audits of the AML compliance program.
  11. Continuous improvement: This section outlines the process for reviewing and updating the AML compliance program on an ongoing basis.
  12. Cross-border transactions: This section explains the procedures for detecting and reporting cross-border transactions that may be related to money laundering.
  13. Correspondent banking: This section outlines the due diligence procedures for correspondent banking relationships, which involve banks providing services to each other.
  14. Political exposure: This section explains the procedures for identifying and managing risks associated with political exposures, such as transactions involving politicians or government officials.
  15. Third-party relationships: This section outlines the procedures for conducting due diligence on third parties, such as service providers, agents, and intermediaries, to ensure they are not facilitating money laundering.
  16. Sanctions screening: This section explains the process for screening transactions and customers against sanctions lists to ensure compliance with sanctions laws.
  17. Anti-bribery and corruption: This section describes the policies and procedures in place to prevent, detect, and report bribery and corruption.
  18. Appendices: This section may include a list of relevant laws and regulations, forms, and other supporting materials.

It’s worth noting that the table of contents of an AML compliance manual may also include additional sections or sub-sections that are specific to the organization’s business and risk profile.

This page was last updated on January 9, 2023.