Whether it's an internal review, an independent test, or a regulatory examination, an AML program review follows a predictable pattern. Here's what happens at each stage and how to prepare.
Organizing documents in advance signals program maturity and makes the review more efficient
An AML program review - whether conducted by an internal auditor, an external compliance consultant, or a regulatory examiner - follows a consistent structure. Understanding that structure in advance allows you to prepare effectively and to present your program in the most favorable light. The review process is not adversarial; it's an evaluation of whether your program meets the regulatory standard. Preparation is the most effective way to ensure a positive outcome.
Document review evaluates completeness, specificity, currency, and consistency of written policies
The review typically begins with a document request. The reviewer will ask for your written AML program, your most recent risk assessment, your training records for the past 12 to 24 months, your CTR and SAR filing history, your independent testing reports, and your customer due diligence records. Organizing these documents in advance - in a clear, accessible format - signals program maturity and makes the review process more efficient.
Transaction testing reveals operational failures that written policies may conceal
The document review phase evaluates the adequacy of your written program against the regulatory standard. The reviewer is looking for: completeness (are all five elements present?), specificity (does the policy describe actual procedures?), currency (has the program been updated recently?), and consistency (does the policy match what the business actually does?). Gaps in any of these dimensions will generate findings.
Staff interviews evaluate whether training has achieved genuine compliance competency
The transaction testing phase involves sampling actual transactions to evaluate whether your monitoring and reporting procedures are working. The reviewer will select a sample of transactions - typically including some that should have generated CTRs or SARs - and evaluate whether the appropriate actions were taken. Transaction testing is where programs that look good on paper often reveal operational failures.
Preparation is the most effective way to ensure a positive review outcome
The staff interview phase evaluates whether your employees understand their compliance obligations. Reviewers typically interview front-line staff, the BSA officer, and senior management. The questions focus on: do employees know what suspicious activity looks like? Do they know how to escalate concerns? Do they know the filing obligations that apply to their role? Staff who cannot answer these questions reveal a training program that hasn't achieved its objective.
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Compliance Program Specialist · Soflo Consulting
Sofia Delgado is a Compliance Program Specialist at Soflo Consulting with expertise in mortgage lender AML requirements, Florida-specific regulatory obligations, and small business compliance program design. She works with non-bank mortgage lenders, title companies, and real estate professionals to build practical, examiner-ready compliance programs.
5 sections
Key Takeaways
- 1Organizing documents in advance signals program maturity and makes the review more efficient
- 2Document review evaluates completeness, specificity, currency, and consistency of written policies
- 3Transaction testing reveals operational failures that written policies may conceal
- 4Staff interviews evaluate whether training has achieved genuine compliance competency
- 5Preparation is the most effective way to ensure a positive review outcome
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