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AMLA Compliance Checklist

1. Client Due Diligence (CDD)

Identify and verify the client's identity

Understand the nature of the client's business

Assess the purpose of the legal services being provided

Conduct ongoing monitoring of the client relationship

2. Risk Assessment

Perform a risk assessment of the firm’s clients and transactions

Classify clients based on risk levels (low, medium, high)

Document the risk assessment findings and procedures

3. Policies and Procedures

Establish and maintain an AML policy

Develop a written compliance program

Ensure procedures are in place for reporting suspicious activities

Include training programs for staff on AML compliance

4. Training and Awareness

Provide regular AML training for employees

Ensure staff understand the AMLA regulations and firm policies

Update training materials with any changes in laws or regulations

5. Record Keeping

Maintain accurate records of client identification and due diligence

Document all transactions and retain records for the required duration

Ensure records are easily accessible for audits or inspections

6. Reporting Obligations

Identify and report suspicious activity to the appropriate authorities

File required reports (e.g., SARs - Suspicious Activity Reports)

Ensure timely and accurate submissions of reports

7. Independent Audit

Conduct periodic independent audits of the AML compliance program

Assess the effectiveness of the AML policies and procedures

Implement recommendations from the audit findings

8. Compliance Officer Role

Designate a compliance officer responsible for AML compliance

Ensure the compliance officer has sufficient authority and resources

Regularly review the compliance officer’s reports and findings

9. Ongoing Monitoring and Review

Regularly review and update AML policies and procedures

Monitor compliance with AML regulations and internal policies

Adjust risk assessments and due diligence processes as necessary

10. Third-Party Due Diligence

Conduct due diligence on third-party vendors and partners

Assess the AML compliance measures of third parties

Document findings and maintain oversight of third-party relationships

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