1. Enterprise AML Program Assessment
William Langford
Director of Global Anti-Money Laundering
JPMorgan Chase & Co.

2. Identify Business Units

3. Assess Risks and Controls
Controls:
Program Governance
Business and Compliance Staffing
Customer Identification and Verification
Customer Due Diligence
Transaction Monitoring
Currency Transaction Reporting
Suspicious Activity Reporting
Training
Compliance Testing
Independent Testing
Risk Factors:
Products and Services Offered
High-Risk Customers
High-Risk Geographies
Business Strategy
Use Metrics to Quantify!

4. Establish Risk Definitions
Assess Quantity of Risk
Assess Quality of Risk Management
Residual Risk

5. Use Regulatory Resources
FFIEC BSA/AML Examination Manual – Appendix J
Comptroller’s Handbook – Large Bank Supervision
Document your standards W

6. Review the Assessments
Ask questions:
Was the assessment completed according to established procedures?
Are risks sufficiently quantified?
Is the assessment of risks and controls consistent with audit and examination findings?
Document your review

7. Compile the Results
Consolidate the results from each business unit into an easy-to-read (and interpret) enterprise-wide overview
Assess the results – where is your institution’s potential exposure?
Develop an executive summary that highlights and quantifies the most significant risks and the quality of risk management
Assess the direction the risk is trending and explain why

8. Communicate the Results
Regulators
BSA Officer
Senior/Exec
Management
Risk
Committees
Testing Units
Auditors
Assessment
Results