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

The USA Patriot Act emphasizes the importance of establishing robust Anti-Money Laundering (AML) programs within financial institutions. Among the components that the Act mandates are an employee training program, designating an internal compliance officer, and implementing an independent audit function. Each of these elements plays a crucial role in ensuring that organizations can effectively detect and prevent money laundering activities.

In contrast, program coordination with the Financial Action Task Force (FATF) is not explicitly required by the USA Patriot Act. While alignment with FATF recommendations can enhance an organization’s compliance and risk management strategies, it is not a mandatory component outlined by the Act itself. This distinction underscores that while international cooperation and adherence to global standards are valuable, they do not constitute a formal requirement for compliance under the legislation. Therefore, the correct answer highlights the lack of obligation concerning coordination with FATF when establishing an AML program as specified by the USA Patriot Act.