Your AML Compliance New Year Checklist for 2024

The start of a new calendar year is the natural reset point for your AML compliance program. Annual training cycles, risk assessment updates, and independent testing schedules all align with the calendar year for most businesses. Taking stock of your 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.

First on the checklist: confirm that your FinCEN registration is current. MSBs must renew their FinCEN registration every two years, and the renewal deadline is easy to miss in the press of daily operations. Check your registration status in the FinCEN MSB Registrant Search and confirm that your registration is current and accurate. If your business information has changed since your last registration, update it now.

Second: schedule your annual AML training for the first quarter. Annual training that is scheduled and completed in Q1 gives you the full year to address any gaps the training reveals, and it ensures that your training records are current well before any examination cycle. If you're using an external training provider, book your sessions now - availability fills up as the year progresses.

Third: review your risk assessment for currency. Has your business changed since the last update? New products, new customers, new locations, new staff? If so, update the assessment now. A risk assessment that doesn't reflect your current business is not a compliant document, and the beginning of the year is the right time to bring it current.

Fourth: schedule your independent testing for the year. If you use an external compliance consultant for independent testing, book your review now. Testing that is scheduled in advance is more likely to happen on time and is more likely to be thorough. If your last independent review was more than 12 months ago, it's overdue - schedule it immediately.

Fifth: review your CTR and SAR filing records for the prior year. Are there gaps? Were all filings made on time? Were there transactions that should have generated filings but didn't? A year-end review of your filing history is a valuable self-assessment tool that can identify program gaps before a regulator does.