Skill

legalcode-aml-kyc-compliance

Design, assess, and gap-analyse Anti-Money Laundering and Know Your Customer compliance programs covering: Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures; beneficial ownership identification (FinCEN CDD Final Rule 31 C.F.R. § 1010.230, Corporate Transparency Act, EU AMLD/AMLR, UK MLR 2017); sanctions screening (OFAC SDN/50% rule, EU Consolidated List, UK OFSI, UN Security Council); Politically Exposed Person (PEP) identification and risk rating; Suspicious Activity Report (SAR) filing procedures (30/60-day deadlines, tipping-off prohibition); Currency Transaction Report (CTR) filing ($10,000 threshold, structuring rules); transaction monitoring rule design (velocity, structuring, behavioral alerts); enterprise risk assessment methodology; BSA/AML five-pillar program governance; employee training requirements; independent audit/testing procedures; and regulatory examination preparation. Aligned with BSA/AML (US), EU AML Package 2024 (AMLR Reg. 2024/1624, Dir. 2024/1640), AMLD6 (Dir. 2018/1673), POCA 2002 / MLR 2017 (UK), and FATF 40 Recommendations. Use when building a new AML/KYC program, assessing an existing program against regulatory expectations, preparing for a regulatory examination, remediating a consent order, or designing a risk-based customer due diligence framework. Produces compliance gap assessments with COMPLIANT / PARTIAL / NON-COMPLIANT / CRITICAL DEFICIENCY classifications, remediation action plans with prioritized timelines, and board-ready program assessment documentation. Jurisdiction-agnostic core with US/EU/UK markers.