Your AML Compliance New Year Checklist for 2023

The start of 2023 brings new compliance obligations, updated regulatory guidance, and the annual reset of training and testing cycles. Taking stock of your AML program at the beginning of the year - before the operational demands of the year take over - is the most effective way to ensure that your compliance obligations are met on schedule and that your program reflects the current regulatory environment.

First priority: review the FinCEN national AML/CFT priorities published in 2021 and confirm that your risk assessment and training program address each relevant priority. The national priorities - corruption, cybercrime, fraud, drug trafficking, human trafficking, terrorist financing, proliferation financing, and transnational criminal organization activity - must be incorporated into your program. If your risk assessment and training content predate the 2021 priorities publication, update them now.

Second priority: confirm your FinCEN registration status. MSBs must renew their FinCEN registration every two years. If your registration is due for renewal in 2023, initiate the renewal process now - don't wait until the deadline. If your business information has changed since your last registration, update it as part of the renewal process.

Third priority: schedule your annual training for Q1. Annual training completed in Q1 gives you the full year to address any gaps the training reveals and ensures that your training records are current well before any examination cycle. If you're using an external training provider, book your sessions now.

Fourth priority: review your independent testing schedule. If your last independent review was more than 12 months ago, schedule a new review for Q1 or Q2. If your testing is current, review the findings from your last review and confirm that all identified issues have been addressed or are on a documented remediation timeline.