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regardless of their business or size, must implement a written AML program that is reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act.
At a minimum, the four point AML program must consist of:
- Incorporate policies, procedures and internal controls reasonably designed to assure compliance with the Bank Secrecy Act
- Designate a compliance officer to assure day-to-day compliance with the program
- Provide for ongoing training of appropriate personnel concerning their responsibilities under the program, including training in the detection of suspicious transactions
- Incorporate policies, procedures and internal controls reasonably designed to assure compliance with the Bank Secrecy Act
- Designate a compliance officer to assure day-to-day compliance with the program
- Provide for ongoing training of appropriate personnel concerning their responsibilities under the program, including training in the detection of suspicious transactions
- Provide for an "independent" review to monitor and maintain an adequate program
In achieving compliance with the BSA / AML, CounterStrike professionals also include (as appropriate):
- Customer Due Diligence (CDD)
- Know Your Customer (KYC)
- Customer Identification Program (CIP)
- Office of Foreign Assets Control (OFAC)
- Currency Transaction Reports (CTR's) and Suspicious Activity Reports (SAR's)
- Evaluation of automated monitoring systems & Management Information Systems
- Adequacy of AML Risk Assessment procedures
- Review of past audit reports to assess the efficacy of implemented changes
And a host of other areas from the Federal Financial Institutions Examination Council (FFIEC) and Financial Crimes Enforcement Network (FinCEN)
Let CounterStrike be your best defense for BSA / AML deferred prosecution agreements, fines and regulatory enforcement actions - contact us today!
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