An acceptable anti-money laundering program must include all but which of the following elements?

An acceptable anti-money laundering program must encompass several critical components to ensure it effectively mitigates the risks associated with money laundering activities. One of these components is the inclusion of a compliance officer, who oversees the program's implementation and adherence to relevant regulations. Training employees about the program and its procedures is also essential to ensure that staff are knowledgeable about the risks and can recognize suspicious activities.

Procedures to meet USA PATRIOT Act reporting requirements are another important element, as these laws set forth guidelines for reporting suspicious transactions and other financial activities that could relate to money laundering or terrorist financing.

The requirement for approval by FinCEN prior to implementation is not mandated within the framework of federal anti-money laundering regulations. While it is important for financial institutions to follow the guidelines set by FinCEN, they do not need to obtain approval before launching their anti-money laundering programs. Instead, institutions are expected to design and implement their programs based on the framework and regulations rather than seeking prior approval. Thus, this element does not belong in a list of required components of an acceptable anti-money laundering program.