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Anti-Money Laundering for Lenders Policy Manual

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Anti-Money Laundering for Lenders Policy Manual

Why you need it:
The Bank Secrecy Act (BSA) is designed to flag law enforcement about potentially illegal activity involving money laundering and other criminal or terrorist activity. The information is coordinated by the Financial Crimes Enforcement Network (FinCEN). Originally, banks were required to have an anti-money laundering policy and loan and finance companies were exempt from the Act; however, in August 2012, the law became effective for these companies as well. 

Residential Mortgage Loan Originator (RMLO) companies are required to implement the Anti-Money Laundering (AML) and Suspicious Activity Report (SAR) section of BSA. Every employee is responsible for understanding the details of the AML/SAR policy to facilitate this effort.

Table of Contents
The Anti-Money Laundering for Lenders Policy Manual features the following sections: 

  • Overview
  • Compliance Officer Designation
  • Suspicious Activity Report Triggers
  • Suspicious Activity Notification to Compliance Officer
  • Optional Resolution Process
  • Suspicious Activity Report Filing
  • SAR Filing Timing Requirements
  • USA PATRIOT Act Section 314(b)
  • Employee Training Programs
  • Independent Testing Function
  • Independent Testing Procedures
  • Customer Identification and Checking the OFAC Lists