T123 · Cat-12 · AML/KYC & Financial Crime · Reporting & Filing

AML Program Gap Auditor

Score AML/BSA program across five FinCEN pillars (31 CFR 1020.210) aligned to FATF Rec. 18: (1) Internal Policies, Procedures & Controls; (2) Designated Compliance Officer; (3) Employee Training; (4) Independent Testing/Audit; (5) Customer Due Diligence. Outputs pillar maturity scores, gap analysis table, prioritised remediation plan, board-ready memo. Distinct from Tool 88 (Product Launch readiness) — this is Internal Program Maturity only. Client-side. Zero PII.

BSAFATFCompliance PostureExport Policy Mandate
Last Reviewed · 2026-05-19
FinCEN 5 Pillars 31 CFR 1020.210FATF Recommendation 18FCA SYSC 6.3OCC BSA/AML Examination ManualBasel Committee Sound Practices 2014
ℹ Distinct from Tool 88 (Product Launch readiness). T123 = Internal AML Program Maturity (FinCEN 5 Pillars) only.
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Educational Use Only This tool provides a self-assessment / educational framework for internal planning purposes only. It is not a regulatory audit, legal advice, or a substitute for a formal compliance review by a qualified advisor. Verify all interpretations against the official source text and applicable RTS/ITS/guidance published by the relevant authority.
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About this tool

Score AML/BSA program across five FinCEN pillars (31 CFR 1020.210) aligned to FATF Rec. 18: (1) Internal Policies, Procedures & Controls; (2) Designated Compliance Officer; (3) Employee Training; (4) Independent Testing/Audit; (5) Customer Due Diligence. Outputs pillar maturity scores, gap analysis table, prioritised remediation plan, board-ready memo. Distinct from Tool 88 (Product Launch readiness) — this is Internal Program Maturity only. Client-side. Zero PII.

Regulatory Coverage
FinCEN 5 Pillars 31 CFR 1020.210
FATF Recommendation 18
FCA SYSC 6.3
OCC BSA/AML Examination Manual
Basel Committee Sound Practices 2014
Analysis Results

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