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November 21, 2024Year-End Compliance Edition
As 2024 draws to a close, it’s time to ensure your AML and financial crime compliance program is ready for year-end reviews and the challenges ahead. Here’s your comprehensive checklist.
📋 The Complete Year-End Checklist
Risk Assessment
☐ 1. Annual enterprise-wide risk assessment – Update for new products, geographies, and customer types
☐ 2. Country/jurisdiction risk rating updates – Incorporate FATF grey list changes
☐ 3. Customer risk rating model validation – Test for accuracy and false positive rates
Policies and Procedures
☐ 4. AML/CFT policy annual review – Document approval by senior management
☐ 5. Sanctions policy update – Reflect 2024 regulatory guidance
☐ 6. Customer due diligence procedures – Align with beneficial ownership requirements
Transaction Monitoring
☐ 7. Rule/scenario tuning review – Analyze alert volumes and disposition rates
☐ 8. Model performance validation – Above/below-the-line testing
☐ 9. Backlog management – Clear aged alerts before year-end
Training and Culture
☐ 10. Annual AML training completion – Achieve 100% completion rate
☐ 11. Specialized training records – Document role-specific training
☐ 12. Board and senior management training – Ensure oversight responsibilities understood
Regulatory Filings and Records
☐ 13. SAR filing accuracy review – Quality control check on filed reports
☐ 14. Record retention audit – Verify minimum 5-year retention compliance
☐ 15. Regulatory exam follow-up – Close any outstanding MRAs/MRIAs
🎯 Priority Items for December
| Priority | Item | Deadline |
|---|---|---|
| 🔴 Critical | Beneficial ownership reporting preparation | Dec 15 |
| 🔴 Critical | Training completion verification | Dec 20 |
| 🟡 High | Risk assessment finalization | Dec 27 |
| 🟡 High | Alert backlog clearance | Dec 31 |
| 🟢 Standard | Policy documentation updates | Dec 31 |
📊 Metrics to Report to the Board
Consider including these in your year-end compliance report:
- SAR filing volumes and trends
- Alert-to-SAR conversion rates
- Training completion percentages
- Audit findings and remediation status
- Key risk indicator trends
- Regulatory examination outcomes
Need assistance with your year-end compliance review? Our team is here to help.