CCO Resource Center: AML Policies and Procedures

Chief Compliance Officer Committee

AML Policies and Procedures

As discussed in more detail in “AML Background,” (link below) the USA PATRIOT Act imposes on financial institutions, including mutual funds, Anti-Money Laundering reporting and recording requirements, as well as requirements relating to customer identification programs (“CIPs”), suspicious activity reporting (“SAR”), foreign correspondent accounts, and private banking accounts. Compliance with these requirements under Federal law require each mutual fund to have compliance policies and procedures address them.  

AML is an area that the SEC’s Division of Examinations inspects when examining registrants. In March 2021, the Division published a Risk Alert to share its observations from AML examinations it had conducted of broker-dealers. While the Risk Alert focuses on broker-dealers’ activities, the Division’s observations may be instructive to mutual funds as they review their AML programs. A link to this Risk Alert is below. 

In May 2020, I was asked by a member of the CCO Committee to collect members’ compliance policies and procedures relating to these requirements. The fourteen policies and procedures I received in response are compiled in this section of the Resource Center. They are ordered from the shortest (3 pages) to the longest (29 pages) of the funds’ policies and procedures; followed by policies and procedures provided to me by three funds that have separate policies and procedures for other financial institutions in their complex in addition to their funds (i.e., broker-dealer, adviser, variable annuity products, ETFs). The multiple policies for these three funds follow those provided to me that only cover their funds’ compliance with the AML requirements. We have made every effort to redact any identifying or proprietary information from these documents. We apologize in advance if we failed to completely redact such information. Please do not share this document with anyone outside of your member firm. As additional members of the Committee share with us their AML policies and procedures, we will add them to this compilation.

The documentation provided by ICI that may be accessed by committee and task force members is restricted to members use only and not for distribution or reproduction. Documentation may be used internally at member organizations as needed to facilitate committee and task force initiatives.