Anti-Money Laundering Program - Preparation is Protection


The Financial Crimes Enforcement Network (FinCEN), a bureau of the Department of the Treasury, recently finalized regulations (Final Rule) requiring non-bank Residential Mortgage Lenders and Originators (RMLOs) to establish an Anti-Money Laundering Program (AML Program) and file Suspicious Activity Reports (SARs), as FinCEN requires of other types of financial institutions.

FinCEN issued these regulations defining non-bank residential mortgage lenders and originators as loan or finance companies for the purpose of requiring them to establish AML Programs and report suspicious activities under the Bank Secrecy Act (BSA).

The effective compliance date for the Final Rule is August 13, 2012.


-What is Money Laundering?

-Minimum Program Requirements

-Risk Assessment

-Risk Profile Review

-Monitoring for Suspicious Activity

-Suspicious Activity Reporting

-SAR Disclosure Prohibition

-Safe Harbor From Liability

-Examination and Enforcement



-Required Reporting

-Timing for filing SAR Reports

-Red Flags

-Training Outline

-SAR Narrative - “The 5 Ws”

-To File Or Not To File

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Jonathan Foxx, Lenders Compliance Group | Attorney Advertising

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