Call us anytime to discuss your Mortgage  Licensing and Compliance requirements: (678) 393-1925
Anti-Money Laundering (AML) Program Check List 

Effective August 13, 2012, non-bank mortgage lenders and brokers must now comply with the Anti-Money Laundering/Suspicious Activity Reporting requirements of the Bank Secrecy Act.  The Compliance Group, Inc. has developed a written AML Program, which is a customized Policy & Procedure.

The written AML Program will give you the substance of it.  

The cost is $795.  Upon receipt of the payment, you will be provided with a draft copy of the AML Program.  Please email RCG Support at: [email protected], to communicate your request to proceed.  Please provide the contact name, legal company name, company address (& billing address, if different), email address, phone number, and your company logo.  Also, indicate if you would like to pay via check or credit card. Once your request is received, we will communicate by sending an invoice, along with payment choice.

For a simple implementation checklist see below:
 
 1. AML Program Policy & Procedures a. incorporate Customer Identification & Verification (CIP) Policy & Procedures 
 
2. Designated Compliance Officer specific to AML Program (AMLCO) 
 
3. Initial & Continuing AML Program Training 
 
4. Suspicious Activity Monitoring 
        a. identifying activities 
        b. internal reporting 
        c. SAR filing determination 
 
5. Filing Suspicious Activity Report (SAR) 
 
6. AML Information Sharing Requirements 
 
7. Annual Audit of AML Program 
 
8. Implement AML Program
Anti-Money Laundering Policy

What is FinCEN’s new AML regulation?
On February 7 2012, the Financial Crimes Enforcement Network (FinCEN) finalized regulations requiring non-bank residential mortgage lenders and originators to establish anti-money laundering programs (AML), and file Suspicious Activity Reports (SARS) which they had previously only required for all banking institutions.  FinCEN is now applying ‘financial institutions’ to include any business entity that makes loans to finance purchases on behalf of consumers and businesses. This would include Mortgage Bankers and Mortgage Brokers.

The AML requirement became effective on April 16, 2012 and the AML program effective date for non-bank compliance is August 13, 2012.

How does my company comply with the AML requirement?Let Mortgage Compliance Advisors put our resources to work for you with our newly developed Anti-Money Laundering Policy Template.  Save valuable time and energy spent writing and implementing an AML policy of your own, and invest in our template to help you secure compliance with new FinCEN requirements.

What’s included in MCA’s AML policy?The cost of MCA’s AML policy is $400 and includes three distinct documents.  Included are the following:

  • Anti-Money Laundering Program Requirements
    This document will help you better understand the new rule and instruct you on how to implement your new AML Policy.
  • Anti-Money Laundering Risk Management Worksheet  
    This document will help you assess your company and identify areas of high risk.
  • Anti-Money Laundering Policy Template
    This document is your actual Anti-Money Laundering Policy Template.
Each of the documents is provided to you in a Word format to allow you to amend to meet your company’s specific needs.

For more information, please contact Sales at (678) 393-1925.

Anti-Money Laundering Policy Manualfor Nonbank RMLORelated Products: mortgage policies, mortgage policy and procedure manualsDo you need a policy to address the implementation of Anti-Money Laundering strategies and Suspicious Activity Reporting? This comprehensive policy manual from AllRegs addresses the requirements of Nonbank RMLOs required by the United States Bank Secrecy Act, USA PATRIOT Act and related regulations as they put their new program into practice. All businesses of any size or structure can make use of this flexible policy which lends itself to deeper implementation as your organization grows.

Get a jump start on this wide-sweeping policy area, create documentation and build accountability with the AllRegs Anti-Money Laundering for Nonbank RMLO Policy Manual.

Updated! This Policy Manual now includes OFAC requirements necessary to fulfill agency requirements for Nonbank RMLOs.

This Policy Manual features sections on the following:

  • Statutes and Regulatory Requirements of
    • Residential Mortgage Lenders and Originators (defined)
    • SAR Filing, SAR Filing System
    • Supervisory User Responsibilities
    • Discrete Filing, Batch Filing
    • Status Tracking, Filing Acknowledgements, E-Filing Alerts, Secure Messaging
    • Exemptions
  • Anti-Money Laundering and Red Flags
  • SAR Reporting
  • Sharing AML Information
  • OFAC and Customer Identification Program requirements under the USA PATRIOT Act

  1. Anti-Money Laundering for Nonbank RMLO Policy Manual BenefitsThe plan features the following benefits:

    • Complete AllRegs Anti-Money Laundering for Nonbank RMLO Policy Manual, saving you development time and resources
    • Get a head start with well-designed and compliant base policy delivered via email within one business day after purchase
    • General guidance on policy development
    • Specific Policy Guidance to help ensure you will not miss anything critical when personalizing your policy
    • Formatted in an editable MS Word document
    • Ability to personalize the plan or manual with your company brand by performing a simple find and replace function
    • Customizable by you, with your internal policies and procedures
    • Ability to add, delete and update your plan to suit the business model of your organization
    • Meet your regulatory or internal compliance requirements
    • Affordable one-time purchase fees
    Easily enhance your employee experience by publishing your manual in AllRegs Online. Your staff can access and search your manual in the same application that they access their AllRegs underwriting guidelines and state and federal regulations. To learn more, call (800) 848-4904.

    Your Plan in Place:AllRegs Policy Manuals have a dual purpose. They are certainly designed for internal use and implementation within your organization. However, many groups or agencies may inquire whether you have a particular plan in place. Click here to compare the implementations and uses of AllRegs Policy Manuals.

    How it Works:When you place your order, we will deliver the Anti-Money Laundering for Nonbank RMLO Policy Manual to you in an editable MS Word document, ready for your company’s personalization and customization. An illustrative guide is included that explains how to add, delete and update your plan to suit the business model of your organization.

    When purchasing AllRegs’ Policy Manuals, you must agree to the License Agreement. The AllRegs Anti-Money Laundering for Nonbank RMLO Policy Manual cannot be shared or sold.

    Note: Changes occur from time to time with the document templates. Updates are not provided to these documents after purchase unless the Policy Manual Maintenance Plan is purchased. They are purchased “as is” at the time of sale.

    Why You Need It:
    • Need to establish your Anti-Money Laundering Nonbank RMLO policies? This document is for you!
    • Save your outsourcing dollars! When you put our Anti-Money Laundering for Nonbank RMLO Policy Manual in place, you won’t need to hire a Consulting, Quality Control or Law Firm to create your plan.
    • Reduce your internal resources’ time allocation on creating policy manuals. You’ll save time and staff efforts when you implement our Anti-Money Laundering for Nonbank RMLO Policy Manual, created based on industry best practices.
    Even better, the following sections were improved as part of a recent revision (03/2014):

    • Updated!
      • Section 1.2: Money Laundering Defined
      • Section 4.1: Penalties – Corporate and Statutory
      • Section 4.2: Nonbank Residential Mortgage Lenders and Originators (RMLO)
      • Section 5.0: Anti-Money Laundering
      • Section 6.2: Transactions Aggregating $5,000 or More
      • Section 6.6: Confidentiality
      • Section 7.0: Sharing AML Information
      • Section 8.0: Office of Foreign Asset Control
    • New! 
      • Section 9.3: Customer Identification Notice

Anti-Money Laundering Policy Manual Details
  • Full Table of Contents:Return to Policy Manual »

    Section 1 Introduction

    • 1.1 Goals and Objectives 
    • 1.2 Money Laundering Defined 
    • 1.3 Senior Management Oversight 
    • 1.4 Compliance Officer Designation 
    • 1.5 Required Review 
    • 1.6 Applicability
    Section 2 Accountability and Monitoring

    • 2.1 Compliance Officer Accountability 
    • 2.2 Internal Monitoring and Controls
    Section 3 Staff and Training

    • 3.1 Ongoing Training 
    • 3.2 New Hire Training 
    • 3.3 Compliance Officer Training
    Section 4 Statutes and Regulations

    • 4.1 Penalties – Corporate and Statutory 
    • 4.2 Nonbank Residential Mortgage Lenders and Originators (RMLO) 
    • 4.3 Anti-Money Laundering Program 
    • 4.4 SAR Filing 
    • 4.5 SAR Filing System 
      • 4.5.1 Supervisory User 
      • 4.5.2 Discrete Filing 
      • 4.5.3 Batch Filing
      • 4.5.4 Status Tracking 
      • 4.5.5 Acknowledgements 
      • 4.5.6 Alerts 
      • 4.5.7 Secure Messaging 
    • 4.6 Exemptions
    Section 5 Anti-Money Laundering

    • 5.1 Red Flags 
    • 5.2 Responding to Red Flags
    Section 6 Suspicious Activity Reporting (SAR)

    • 6.1 Identification Required 
    • 6.2 Transactions Aggregating $5,000 or More 
    • 6.3 Filing of Reports 
    • 6.4 Senior Management Notification 
    • 6.5 Electronic Reporting 
    • 6.6 Confidentiality 
    • 6.7 Safe Harbor 
    • 6.8 Record Retention
    Section 7 Sharing AML Information

    • 7.1 FinCEN and Other Federal Law Enforcement 
    • 7.2 Research Limits 
    • 7.3 Nondisclosure 
    • 7.4 Sharing Information with Other Financial Institutions
    Section 8 Office of Foreign Asset Control

    • 8.1 Customer Information Required 
      • 8.1.1 Information for Identification of Individuals 
      • 8.1.2 Information for Identification of Businesses 
      • 8.1.3 Existing Customers 
      • 8.1.4 Reasonable Belief 
      • 8.1.5 Identification Using Nondocuments 
    • 8.2 Office of Foreign Asset Control (OFAC) 
    • 8.3 Tax Payer Identification Requirement 
    • 8.4 Record Retention 
    • 8.5 Notice Required
    Section 9 Appendix

    • 9.1 Suspicious Activity Investigation Report 
    • 9.2 Table of Relevant Nonimmigrant Visa Classes 
    • 9.3 Customer Identification Notice
  1. Fees and Fulfillment
    • The AllRegs Anti-Money Laundering for Nonbank RMLO Policy Manual is available for a one-time fee of $545 for the standard manual.
      • For standard policy manuals, agreement to our License Agreement is required, and the template cannot be shared or sold.
      • After you place your order, you will receive the document via email within one business day.
    • Customize this policy manual with the Make it MINE option for $825, for a total policy manual fee of $1,370.
    • Add the Maintenance Plan to your Policy Manual to receive at least one annual update per year.
      • The Maintenance Plan is $100 annually for Standard Policy Manuals or $425 annually forMake it MINE Manuals.
    • Identify your Make it MINE and Maintenance Plan options when you add this product to your cart.
    Anti-Money Laundering for Nonbank RMLO Policy ManualAnti-Money Laundering for Nonbank RMLO Policy Manual and Maintenance PlanMake it MINEAnti-Money Laundering for Nonbank RMLO Policy ManualMake it MINEAnti-Money Laundering for Nonbank RMLO Policy Manual and Maintenance PlanProduct Price$545 / manual$100 / year$825 / manual$425 / yearTotal Price$545$645$1,370$1,795

    For more information, call our sales and customer service department at (800) 848-4904 or email [email protected].