Anti-Money Laundering Policy Manual

Do 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.

Overview

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.

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

This Anti-Money Laundering Policy Manual covers the following topics:

  • Introduction
  • Accountability and Monitoring
  • Staff and Training
  • Statutes and Regulations
  • Suspicious Activity Reporting (SAR)
  • SAR Filing System
  • AML Red Flags
  • Sharing AML Information
  • Office of Foreign Asset Control
  • Appendix


Benefits

The policy 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
  • Formatted in an Microsoft Word file
  • Meet your regulatory or internal compliance requirements
  • Affordable one-time purchase fees

Optional Services

Maintenance: Receive regular and ongoing industry updates to keep your policy within regulatory requirements.

Publishing: Publish your manual, including your company procedures, in AllRegs Online to complete your policy manual solution.

Contact your account manager for information regarding these optional services!


Policy Manual
Anti-Money Laundering
Section Title Priority Action
1.1 Goals and Objectives Mandatory Review Include the point of view or culture of your organization in this section, if applicable.
1.2 Required Review Mandatory Review Be sure this accurately reflects your company’s annual policy review process.
1.5 AML Risk Assessment Mandatory Review This policy calls for a comprehensive analysis of the AML risks within the organization. The results of this analysis will aid in development of the AML compliance program so that identified risks are mitigated. Ensure this section aligns with your organization’s risk assessment program.
1.7 AML Compliance Officer Designation Mandatory Review This policy provides for the appointment of an AML Compliance Officer, even if that individual is also the corporate Compliance Officer. This should be clarified here.
2.1 Internal Monitoring and Controls Mandatory Review Include or reference related procedures for independent testing in this section.
2.2 AML Compliance Officer Accountability Recommended Best Practice Specific duties and responsibilities of the AML Compliance Officer should be included here.
2.3 Board of Directors and Senior Management Oversight Mandatory Review Modify as necessary to reflect your management structure.
3 Staff and Training Mandatory Review Include the means by which your organization provides and tracks required training.
4.1 Penalties – Corporate & Statutory Mandatory Review The “Corporate” section should be modified to reflect your internal penalties affecting employees.
4.5.2 AML Program Risk-Based Requirements Recommended Best Practice Edit this section as desired to add references to any applicable procedures or processes used by your organization to perform due diligence, collect information, and assess risk.
5.4 FFIEC Red Flags Recommended Best Practice Edit or amend this section with those indicators or events experienced by your organization and/or within your market.
7 AML Red Flags Recommended Best Practice Edit or amend this section with those indicators or events experienced by your organization and/or within your market.
7.1 Responding to Red Flags Recommended Best Practice Edit the list of employee responses to red flags to reflect your internal escalation process.
9.1 Customer Information Required Recommended Best Practice Modify as needed to match your process for implemntation of a Customer Identification Program and Notice under OFAC requirements.