In addition to setting up your compliance program and training staff, you’ll need to conduct an AML Compliance Effectiveness Review every two years. This is a review of your compliance program (your documentation that describes what you do) and your operations (evidence of what you’ve actually done). The review can be conducted internally (by someone at your company) or by a third party (someone outside of your company). Reviews must be conducted by someone who is knowledgeable of AML requirements. Also, reviews should be impartial, meaning it should not be conducted by someone who is directly involved in your compliance program activities. Still not sure? Take a look at our blog on AML Compliance Effectiveness Reviews.
If you want someone to conduct your AML Compliance Effectiveness Review for you (there is a fee, but CJA members receive a 10% discount), you can contact us using our online form, or call us at (844) 919-1623.