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AML/KYC policy and procedure manual

An AML/KYC manual drafted against the FATF Recommendations, Directive (EU) 2015/849 and the Bank Secrecy Act, reviewed by our legal team.

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$3,000 to $5,000, fixed before we start. First draft in 15 working days.

Updated

PD-AM; specimen page

AML/KYC manual

Contents

  1. 1AML/CTF policy
  2. 2Customer due diligence and KYC procedure
  3. 3Enhanced due diligence procedure
  4. 4Transaction monitoring and suspicious activity reporting procedure
  5. 5Record-keeping and training schedule
  6. 6Risk assessment template

1Purpose

1.1An AML/KYC manual is the document that sets out how a firm assesses its money laundering and terrorist financing risk, identifies and verifies its customers, monitors their activity, reports suspicion and proves that all of it happened.

Specimen: the first page of the AML/KYC manual, as delivered

What it is

An AML/KYC manual is the document that sets out how a firm assesses its money laundering and terrorist financing risk, identifies and verifies its customers, monitors their activity, reports suspicion and proves that all of it happened. AML stands for anti-money laundering and KYC for know your customer.

Who it is for

A money services business applying for a licence, a fintech whose banking partner has asked to see its AML programme, a payments or digital asset firm registering with FinCEN or a European supervisor, or an established firm whose manual was written for a rulebook that has since changed. The manual is drafted for the compliance officer who will run it and the examiner who will read it, so each procedure says who does what, when, and what gets recorded.

What you get

6 deliverables, in Word (.docx) and PDF, with one round of revisions.

  • AML/CTF policy
  • Customer due diligence and KYC procedure
  • Enhanced due diligence procedure
  • Transaction monitoring and suspicious activity reporting procedure
  • Record-keeping and training schedule
  • Risk assessment template

What each document answers

Each document in the manual is drafted against a named rule: a FATF Recommendation, an article of Directive (EU) 2015/849 and, where one applies, a US provision.

DocumentRule it is drafted against
AML/CTF policyFATF Recommendation 18 (internal controls); Article 8(3) to (5) of Directive (EU) 2015/849; 31 U.S.C. 5318(h), and 31 CFR 1022.210 for a money services business
Customer due diligence and KYC procedureFATF Recommendation 10; Articles 11, 13 and 14 of Directive (EU) 2015/849; 31 CFR 1022.210(d)(1) for a money services business, 31 CFR 1010.230 (beneficial owners) for a covered financial institution
Enhanced due diligence procedureFATF Recommendation 12 (politically exposed persons); Articles 18 to 23 of Directive (EU) 2015/849
Transaction monitoring and suspicious activity reporting procedureFATF Recommendations 10 (ongoing due diligence), 16 (payment transparency, where you send or receive wire transfers) and 20 (reporting); Articles 13(1)(d) and 33 of Directive (EU) 2015/849; 31 CFR 1022.320 for a money services business, otherwise the SAR rule in 31 CFR Chapter X for your sector
Record-keeping and training scheduleFATF Recommendations 11 (record-keeping) and 18 (training); Articles 40 and 46(1) of Directive (EU) 2015/849; 31 CFR 1010.430(d), and 31 CFR 1022.210(d)(3) for training at a money services business
Risk assessment templateFATF Recommendation 1 (risk-based approach); Article 8(1) and (2) of Directive (EU) 2015/849

Most manuals fall apart at the escalation step: a transaction is flagged and nobody can say who decides, by when, or where the decision is written down. Ours names the person, the deadline and the record.

What it costs

$3,000to $5,000

The AML/KYC manual is $3,000 to $5,000. The quote is fixed before we start and does not change. Maintenance is a separate plan, $29 to $99 a month, that keeps the AML/KYC manual current when a rule it names changes.

How the document is made, from intake to delivery, is set out in how it works.

Band
Bespoke manual
First draft
15 working days
Revisions
One round included
Review
Our legal team, before delivery
Format
Word (.docx) and PDF
Maintenance
$29 to $99 a month

What we need from you

The intake asks which regulator supervises you, what products you offer and to whom, where your customers are, how you onboard them, which screening and monitoring tools you use, who your compliance officer reports to, and how suspicious activity has been escalated so far. Name your current manual and risk assessment if you have them, and send them once we reply. Where you have no answer, the intake offers the common options and you pick one.

How it is drafted and reviewed

We draft from the intake against the FATF Recommendations, Directive (EU) 2015/849 as amended, the Bank Secrecy Act and the FinCEN rules in 31 CFR Chapter X for your sector, and your regulator's rulebook, in the order an examiner expects: risk assessment, then policy, then the procedures that carry it out. Our legal team reviews the draft before delivery and records the review in the revision block. You mark changes and we revise once. The manual arrives in Word and PDF with a document ID and revision code. We keep the final version on file for the maintenance plan.

Drafted against

  • FATF Recommendations 1, 10, 11, 12, 16, 18 and 20 (2012, as amended)
  • Directive (EU) 2015/849 as amended
  • Bank Secrecy Act, 31 U.S.C. 5311 and following, with the FinCEN rules in 31 CFR Chapter X for your sector (31 CFR 1022.210 for a money services business; 31 CFR 1010.230 for a covered financial institution)
  • The rulebook of the regulator you name in the intake

What maintenance covers

When the rule changes, your document changes. Under the maintenance plan we track the FATF Recommendations, Directive (EU) 2015/849 and the FinCEN rules you were drafted against, issue a revised manual with the changes marked, and keep the document ID and revision history current. Directive (EU) 2024/1640 repeals Directive (EU) 2015/849 with effect from 10 July 2027, and from that date the duties on firms sit mainly in Regulation (EU) 2024/1624. Without the plan, the manual is still yours to use and to edit; it simply stops being tracked.

$29to $99a month, optional

Questions about the AML/KYC manual

Which regulator is the AML/KYC manual written for?
The AML/KYC manual is written for the regulator you name in the intake. The FATF Recommendations, Directive (EU) 2015/849 and the FinCEN rules in 31 CFR Chapter X give the manual its structure; your regulator's rulebook gives each procedure its thresholds, deadlines and forms. A firm with more than one regulator is scoped in the intake and quoted before drafting starts.
Does the AML/KYC manual settle our AML obligations?
No AML/KYC manual settles a firm's AML obligations on its own. The manual is drafted against the FATF Recommendations, Directive (EU) 2015/849 and the Bank Secrecy Act, and structured the way examiners expect to read it. Running it, training staff and filing reports is your firm's responsibility; the document is drafted from your intake and reviewed by our legal team before delivery.
Can you draft from our existing AML/KYC manual?
An existing AML/KYC manual can be the starting point: name it in the intake, with your last risk assessment, and send both once we reply. The new draft keeps what still matches the rule, rewrites what does not, and marks every change so your compliance officer can see what moved.
How long does an AML/KYC manual take to draft?
The first draft of the AML/KYC manual is delivered 15 working days after a complete intake. Your review and the one revision round add whatever time you need.

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