When developing an AML program for a bank, at minimum, what should the plan cover?

• A. A detailed marketing plan to attract new customers.
• B. A compliance manual focused on FINRA guidelines.
• C. An assessment of money laundering risk and procedures to mitigate it.
• D. An annual report on product pricing.

Answer: (C)

The essential element is establishing a risk-based plan that identifies money laundering risks and lays out the controls to mitigate them. This means a formal risk assessment that covers customers, products and services, delivery channels, and geographies, paired with procedures to address and reduce the identified risks—such as customer due diligence, ongoing monitoring, and suspicious activity reporting. The other options don’t provide the risk-focused framework and controls AML programs require: a marketing plan targets growth, a manual anchored to securities guidelines isn’t the bank’s AML baseline, and a pricing report has no AML relevance.