Which essential component is not required by the USA Patriot Act for establishing an AML program?

The correct answer is that program coordination with the Financial Action Task Force (FATF) is not a required component by the USA Patriot Act for establishing an Anti-Money Laundering (AML) program.

The USA Patriot Act emphasizes several critical elements for an effective AML program, including the necessity for an employee training program, which ensures that employees are aware of the signs of money laundering and understand the policies in place. An internal compliance officer is also essential, as this individual is responsible for overseeing the AML efforts and ensuring that the program is executed effectively. Additionally, having an independent audit function is important to assess the effectiveness of the AML program and uncover any potential weaknesses.

While aligning with international standards and organizations such as the FATF can enhance an institution's AML efforts, the USA Patriot Act itself does not mandate direct coordination with FATF. Instead, it focuses on internal policies, training, oversight, and audit mechanisms to combat money laundering within the U.S. legal framework. Therefore, this makes coordination with FATF non-essential in meeting the requirements defined by the USA Patriot Act.