Which statement best describes the relationship between the Patriot Act and AML program requirements?

• A. The Patriot Act imposes no AML requirements.
• B. AML programs are optional under the Patriot Act.
• C. The Patriot Act requires ongoing AML program training.
• D. AML programs are prohibited by the Patriot Act.

Answer: (C)

Ongoing training is required as part of an AML program under the Patriot Act. This ensures staff can recognize red flags, understand how to escalate and report suspicious activity, and stay updated on regulatory changes and evolving money-laundering schemes. Training isn’t a one-time event; it must be continuous so the program remains effective as methods of laundering evolve. AML programs typically include internal controls, a designated compliance officer, independent testing, ongoing training, and suspicious activity reporting. The idea that there are no AML requirements, that training is optional, or that AML programs are prohibited is not accurate—the Patriot Act strengthens and mandates these defenses.