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AML Compliance Programme

Compliance Risk and ControlsUpdated 15 Nov 2026

An AML compliance programme is the British and international spelling of what the main entry calls an AML program: the framework of policies, procedures, controls, staff and systems that a regulated firm uses to prevent, detect and report money laundering and terrorist financing.

Most programmes share the same core elements, whatever the country. They include a business-wide risk assessment, customer due diligence, transaction monitoring, sanctions screening, suspicious activity reporting, record keeping, staff training, a named officer responsible for compliance and independent testing. In the United States, these are often summarised as the "pillars" required under the Bank Secrecy Act. In the UK and EU, the duty to run such a programme comes from money laundering regulations and directives, with a money laundering reporting officer at its centre.

The terms are interchangeable, though "programme" is used in UK, European and Commonwealth guidance and "program" in US law. Some firms also say "AML/CFT programme" to stress that it covers counter-terrorism financing as well as anti-money laundering.

Last updated 15 Nov 2026