Anti-Money Laundering

Our audit process is an in-depth review and Testing of all Anti-Money Laundering policies, procedures, review processes and record retention. As part of the audit we review the major procedures involving:

 

  • Management Oversight
  • Document Retention
  • Money Transfer Controls
  • Suspicious Activity Reporting
  • Account Opening
  • Training
  • Customer Activity Monitoring

  • Including the following areas, processes, and procedures:

    • General compliance with the USA Patriot Act of 2001
    • Compliance with FINRA Rule 3011
    • The adequacy of the AML Policies and Procedures
    • Currently Implemented methods of Customer Identification
    • Use of outside vendors to assist in Customer Identification
    • Compliance with OFAC requirements
    • Compliance with FinCEN Section 311 Notification
    • Compliance with FinCEN 314a requests
    • Compliance with FinCEN Section 312 requirements
    • Training program
    • AML Compliance interaction with the AML program
    • AML Compliance Officer notification and escalation process
    • Red Flags
    • Wire Transfers
    • SWIFT Transfers
    • E-mail and Instant Message review and oversight
    • Previous Audit Results
    • Dissemination of AML policies and Procedures to employees
    • Emergency Notification Procedures (Filing of Suspicious Activity Reports)

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