AML Program Template PDF Details

An effective anti-money laundering (AML) program rests on five core pillars established by federal regulators: internal controls, a designated compliance officer, ongoing employee training, independent auditing, and customer due diligence. The AML program template in this PDF documents each of these pillars, giving your organization a ready-to-customize compliance framework that satisfies requirements under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Money Laundering Control Act of 1986, and rules enforced by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).

The template captures specific compliance procedures that regulators require. These include customer identification and verification processes, thresholds for filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), recordkeeping timelines for transaction data, and the scope of employee training programs. It also documents the compliance officer role, outlining their authority to approve transactions, escalate suspicious activity, and liaise with law enforcement. Organizations that complete this template can demonstrate to examiners that their AML program is written, implemented, and regularly reviewed, which is a baseline requirement for financial institutions under the Bank Secrecy Act.

A wide range of regulated entities rely on AML program templates. Banks, credit unions, broker-dealers, and insurance companies must maintain written AML programs under federal law. Money services businesses (MSBs) such as currency exchanges, check cashers, and prepaid card issuers face similar obligations under FinCEN regulations. Nonprofits, universities, and other institutions that handle significant financial flows also adopt AML policies to mitigate exposure to money laundering or terrorist financing risks. This George Washington University policy document is a practical example of how an educational institution structures its anti-money laundering compliance commitments.

For related compliance forms, see the Wolfsberg Anti-Money Laundering Form and the DEFRA AML Form 2. Organizations seeking to build a full KYC program can also reference the KYC verification form templates available on FormsPal.

QuestionAnswer
Form NameAML Program Template
Form Length3 pages
Fillable?No
Fillable fields0
Avg. time to fill out45 sec
Other namesanti money laundering template, AML policy template, anti money laundering program template, anti money laundering policy sample, BSA AML policy template, AML compliance program template, money laundering policy template

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Responsible University Official:

Senior Associate Vice President for

Finance

Responsible Office: Treasury

Management

Origination Date: October 2005

Last Amended Date: June 26, 2014

ANTI-MONEY LAUNDERING POLICY

Policy Statement

It is the policy of the George Washington University to comply with anti-money laundering obligations imposed by the federal government, including applicable provisions of the Money Laundering Control Act of 1986, the Bank Secrecy Act, the USA PATRIOT Act of 2001, the rules and regulations overseen by the United States Treasury Department’s Office of Foreign Assets Control and Financial Crimes Enforcement Network, and other legal requirements.

Reason for Policy/Purpose

The purpose of this policy is to enhance the university’s compliance with anti-money laundering laws and regulations, to assist law enforcement in combating illegal money laundering, and to minimize the risk of university resources being used for improper purposes. Failure to comply with anti-money laundering regulations could result in civil and criminal penalties to the university and/or individual faculty, staff and students.

Who Needs to Know This Policy

 

Faculty, staff, and students

 

Table of Contents

Page #

Policy Statement

1

Reason for Policy/Purpose

1

Who Needs to Know This Policy

1

Table of Contents

1

Policy/Procedures

2

Website Address for This Policy

2

Contacts

2

Related Information

3

Who Approved This Policy

3

History/Revision Dates

3

ANTI-MONEY LAUNDERING POLICY

Policy/Procedures

Money laundering is conducting or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activity. To assist the federal government in detecting, preventing, and eradicating criminal and terrorist financing and activity, the university will take all necessary steps to comply with applicable anti-money laundering laws and regulations.

The university will maintain an anti-money laundering program in accordance with the Bank Secrecy Act, as amended by the USA PATRIOT Act, and other applicable federal laws and regulations. The program is reasonably designed to prevent university services from being used to facilitate money laundering and the financing of terrorist activities. The program includes the following:

•Procedures to verify customer identification and retain necessary identifying and transactional information;

•A designated compliance officer to coordinate compliance with the program;

•Suspicious activity reporting procedures and document retention guidelines for any suspicious activity reports and supporting documentation;

•Training and education of appropriate university personnel concerning their responsibilities under the program, including suspicious activity reporting; and

•Independent review to monitor and maintain an adequate program.

Concerns regarding transactions that are unusually large or that appear suspicious and questions regarding money laundering in general should be directed to the university’s Treasury Management Office at 202-994-0985.

Website Address for This Policy

GW University Policies

Contacts

Subject

Contact

Phone

Money

Treasury Management

703-726-4216

Laundering

 

 

2

ANTI-MONEY LAUNDERING POLICY

Related Information

Bank Secrecy Act, 12 U.S.C. §1951, et seq.

31 U.S.C. § 5311, et seq.

31 C.F.R. Part 1010, 1022

Money Laundering Control Act of 1986, Public Law 99-570 USA PATRIOT Act of 2001, Public Law 107-5

A Brief Primer on Doing Business Abroad: U.S. Laws that Affect GW’s International Activities

Compliance with Law when Conducting University Activities Overseas

Who Approved This Policy

Louis H. Katz, Executive Vice President and Treasurer

Beth Nolan, Senior Vice President and General Counsel

History/Revision Dates

Origination Date:

October 2005

Last Amended Date:

June 26, 2014

Next Review Date:

June 30, 2015

3

How to Edit Aml Program Template Online for Free

Our online PDF editor makes it straightforward to complete the AML compliance program template. Follow these steps to fill out your anti-money laundering policy document and save a copy for your records.

Step 1: Click the "Get Form Here" button to open the AML program template in the FormsPal editor.

Step 2: Once the editor loads, the toolbar at the top of the page gives you tools to type text into fields, add your organization's information, and navigate between pages. The template spans three pages covering the policy overview, compliance procedures, and approval history.

The following sections will appear in the PDF document you are completing:

anti money laundering policy sample empty spaces to consider

Enter your organization's details in the fields for Bank Secrecy Act compliance references (USC citations), the name of the approving authority, the compliance officer designation, history and revision dates, origination date, last amended date, and next scheduled review date.

anti money laundering policy sample Bank Secrecy Act USC et seq USC, Who Approved This Policy, Louis H Katz Executive Vice, HistoryRevision Dates, Origination Date, October, Last Amended Date, June, Next Review Date, and June fields to complete

Step 3: After filling in all required fields, click "Done" to finalize the document. You can then download the completed AML program template to your device or send it by email.

Step 4: Save at least two copies of the completed form. Keep one on file for internal compliance audits and retain a second copy in a secure location as required by Bank Secrecy Act recordkeeping obligations.

Need additional anti-money laundering compliance documents? FormsPal also offers the Wolfsberg AML questionnaire form and DEFRA AML Form 2 for organizations that need multiple compliance templates.

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