Anti-Money-Laundering Compliance Summary

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Anti-Money-Laundering Compliance Summary"

Transcription

1 Anti-Money-Laundering Compliance Summary It is imperative that futures industry professionals, who may be susceptible to money-laundering schemes, be cognizant of their responsibilities and follow proper procedures to avert illegal activity. NFA Compliance Rule 2-9 (c) and its related Interpretive Notice establish certain standards and requirements to thwart, detect, and report attempted and actual money laundering. Three areas are most relevant for the prevention of money laundering: customer identification programs, monitoring accounts for suspicious activity, and reporting of suspicious activity, and are further discussed below. Customer Identification Program (CIP) To help the government in the fight against terrorism and money-laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account. The following highlights the principal aspects of a futures industry customer identification program. Every FCM and IB has an obligation to establish and implement an independent customer identification and verification program. The Know Your Customer requirement of NFA Rule 2-9 (c), dealing with anti-moneylaundering (AML) programs differs from the Know Your Customer requirement of NFA Rule 2-30, pertaining to account openings. 1. NFA Rule 2-9 (c) applies to all accounts, and its purpose is to ascertain: who is the customer; what is the customer s business; and what is the intended purpose of the customer s transactions. 2. NFA Rule 2-30 applies only to individual accounts and has as its objective sufficient knowledge of the customer to assure adequate risk disclosure. The minimum information that must be obtained and appropriately maintained to accomplish the objectives of a firm s AML customer identification program is: 1. For all accounts, the customer s name and address; 2. For accounts of natural persons, the customer s date of birth; 3. For accounts of non-natural persons, the customer s principal place of business; 4. For accounts of a US person, the customer s social security number or taxpayer identification number (TIN); 5. For a natural person who is not a U.S. person, the customer s tax identification number, current passport number and country of issuance, alien identification card number, or the number and country of issuance of any other valid government identification document that bears a photograph or other biometric identifier. Other documents required for a client to open an account also may be useful in identifying the client such as driver s license or other identifying documents. A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, 1

2 certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement. CIP requirements do not apply to futures accounts that existed as of October 1, 2003 and accounts obtained by acquisition of another firm provided that the firm where the account currently resides has reason to believe it knows the true identity of the customer. Certain customer behavior during the account opening process or subsequently may signal the need for further investigation by the firm. Examples include customers: 1. Who are excessively secretive about their identity, type of business or source of assets; 2. Who are disinterested in the costs and/or risks of futures trading; 3. Who appear to be acting as agents for other entities or individuals and who are evasive about the agency relationship and/or the other entities or individuals; 4. Whose appearance or response to questions is inconsistent with the customers documents or previous statements; 5. Who have corporate accounts and lack knowledge of their entities businesses or industries; 6. Who are from jurisdictions identified as problem areas for money laundering, terrorist financing, narcotics production, or bank secrecy. For prospective accounts from such jurisdictions a firm should determine what, if any, additional due diligence is necessary in deciding whether to accept the account and, if accepted, what, if any, additional monitoring is required. Firms must have procedures to identify potentially high-risk accounts that, for whatever reason, are judged to be particularly vulnerable to money laundering. These procedures must provide for the enhanced verification of customer identity as well as continuing monitoring of such accounts if they are accepted. For high-risk customers who are not individuals, firms also must obtain identifying information about those persons who have authority or control over the accounts. FCMs and IBs should monitor FinCEN's website at for information on foreign jurisdictions, institutions, classes of transactions, or types of accounts that have been designated as a primary money-laundering concern, and any special measures that have been imposed. Because certain types of entities and those from certain geographic locations are especially vulnerable to money laundering, firms should consult lists of high-risk countries, including non-cooperative jurisdictions and restricted countries subject to sanction by the Office of Foreign Assets and Control (OFAC). Firms also must check OFAC s list of Specially Designated Nationals and Blocked Persons (SDN list) that contains names of suspected or known terrorists or terrorist organizations and notify OFAC if an account applicant s name appears on the list. The OFAC and information on how to handle matches can be found at The Financial Action Task Force's (FATF) serves as the global standard setting body for antimoney laundering and combating the financing of terrorism. FATF identifies jurisdictions that have strategic deficiencies and works with them to address deficiencies that pose a risk to the 2

3 financial system. Because certain types of entities, individuals and those from certain geographic locations are especially vulnerable to money laundering, firms should regularly consult the FATF's public statements/advisories at as changes may affect U.S. financial institutions obligations and risk-based approaches with respect to relevant jurisdictions. If the customer is from one of the jurisdictions countries/territories identified as having Anti- Money-Laundering and Counter-Terrorism Financing Act (AML/CFT) deficiencies on the list of Non-Cooperative Countries and Territories (NCCT list), the FCM or IB should determine what, if any additional due diligence is necessary in deciding whether to open the account, and if the account is accepted, what, if any, additional monitoring of the account activity is appropriate. Verification of a customer s identity must occur within a reasonable period of time before or after an account is accepted. Such verification may include use of information from consumer reporting agencies, public databases and other sources. There may be situations where an FCM or IB cannot form a reasonable belief that it knows the true identity of the customer and the firm must have procedures in place to address how to handle such occurrences. At a minimum, these procedures should address: (1) when an account should not be opened; (2) the terms under which a customer may conduct transactions while the FCM or IB attempts to verify the customer's identity; (3) when an account should be closed after attempts to verify a customer's identity have failed; and (4) when the FCM or IB should file a Suspicious Activity Report (SAR) in accordance with applicable laws and regulations. Monitoring Accounts to Detect Suspicious Activity The detection and reporting of suspicious activity are central to the AML programs of all US financial services firms, including FCMs and IBs. The specific aspects of a firm s monitoring program normally are tailored to the size of the firm, the nature of its business and client base, and the types of accounts the firm handles. Suspicious activity includes transactions that, in view of the particular customer s business, investment objectives and/or normal trading patterns: Have no obvious business or portfolio purpose; Have no apparent lawful purpose; Are atypical for that customer; Lack a reasonable explanation. In general, it is at the account opening stage, when a firm implements its customer identification program, that the firm identifies potential accounts whose economic or business purpose is not readily apparent. As mentioned previously, at account opening certain types of customer behavior may be considered suspicious, and the firm, if it accepts such an account, may determine that the account requires enhanced scrutiny thereafter. In perhaps the more normal course for many FCMs and IBs, particularly in cases where accounts are not opened in person, it may be only after trading has begun that the firm 3

4 observes suspicious activity, for example, transactions that appear to be inconsistent with what the firm knows about the customer. At such time the firm would determine that the account requires heightened scrutiny. Certain types of transactions normally require heightened monitoring for all customers. These include: Unusual deposits in terms of their size, source, and/or number; Unusual transfers in terms of their size, destination, and/or number; Wash and fictitious trades; Significant third-party transfers and deposits; Significant wire and/or cash deposits or transfers, including individual or a series of transactions involving more than $5,000 in currency or cash equivalents. While there may be valid explanations for such transactional red flags, a futures industry firm should investigate and determine if there is a plausible explanation for each transaction individually and for the transactions in their totality. In all cases of suspected unlawful activity the futures industry firm and its employees must maintain an adequate audit trail. Suspicious Activity Reporting It is the responsibility of futures industry firms to establish clear reporting lines so that all staff members, non-registrants as well as registrants, who are in a position to observe suspicious activity understand how and to whom to report their observations in a timely fashion. NFA Rule 2-9(c) and its accompanying Interpretive Notice require all FCMs and IBs, as part of their AML plans, to designate an individual or individuals to oversee the firm s Anti-Money-laundering Program. Such a compliance officer must be independent and must report ultimately to the firm s senior management The responsibilities of a firm s AML officer include: Investigating suspicious conduct and activity; Evaluating and determining whether such conduct and activity warrant reporting to the firm s senior management; If authorized to do so, reporting such conduct and activity to the U.S. Treasury s Financial Crimes Enforcement Network (FinCEN). Generally, a Suspicious Activity Report by the Securities and Futures Industries (SAR) must be made for any suspicious futures or futures options transaction of $5,000 or more that may involve a violation of law, except for violations that must be reported by FCMs and IBs under futures laws and regulations or the rules of a futures industry self-regulatory organization (SRO). Suspected violations of the Bank Secrecy Act must be reported in a Suspicious Activity Report. A SAR generally should include the following, if known: 4

5 A description of the activity that prompted the report, including the type(s) of activity; The date or range of dates on which the activity took place; A notation whether the transaction was completed or only attempted and whether it was an isolated incident or related to one or more other transactions; An explanation of who benefited from the transaction and how much they received; Other information identifying the transaction, such as its size or dollar amount, currency(ies) involved, where the activity took place, the financial instrument(s) involved, and securities CUSIP or ISID numbers; A description of any admission, explanation, or attempted cover-up of the transaction; Identifying information concerning the account in which the activity took place and/or the account holder; Whether another law enforcement authority has been contacted. As appropriate, a SAR should include recommendations for further investigation that might assist law enforcement authorities. A SAR normally must be made within 30 days of a firm becoming aware of a suspicious transaction, but may be delayed an additional 30 days to identify a suspect. In situations in which timing is critical, immediate telephone contact with appropriate authorities should be made, in addition, to filing a timely written SAR. A copy of the SAR and all supporting documentation must be maintained for five years from the date the SAR was filed. Guidance Regarding the Sharing of SARs and Maintaining Confidentiality Futures industry personnel are barred by federal law from disclosing that a SAR was filed to the person involved in the transaction, the content of a SAR, or to disclose any information that would reveal the existence of a SAR. This disclosure prohibition applies to all persons, except as specifically authorized by regulation 31 CFR The regulation provides that FCMs and IBs are permitted to make SARs and related SAR information available to the National Futures Association (NFA) only upon the request of the Commodity Futures Trading Commission (CFTC). However, in January 2014, the CFTC amended the regulation and requested that all FCMs and IBs to make the following available to upon BFA's request: SARs; Information revealing the existence or non-existence of SARs; and SAR supporting documentation. Such a request may relate to any examination, investigation or for risk assessment purposes. FCMs and IBs may share a SAR, or any information that might reveal the existence of a SAR, with an affiliate, provided that affiliate is subject to a SAR regulation issued by FinCEN or another regulatory agency. These regulatory agencies may include the Board of Governors of 5

6 the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision and the Securities and Exchange Commission. However, the affiliate shall not share the existence of the SAR, or any information that would reveal the existence of the SAR, with another affiliate, even if that affiliate is subject to a SAR rule. In addition, futures industry firms, as part of their internal controls, must have policies and procedures in place which ensure that its affiliates protect the confidentiality of the SAR, including limiting access to a "need-to-know" basis, as well as establishing restricted areas for reviewing SARs, maintaining a log of access to SARs, using cover sheets for SARs or supporting documentation that indicates the filing of a SAR, or using electronic notices that highlight confidentiality concerns before a person may access or disseminate the information. Conclusion Firms and their personnel must ensure that they take adequate steps to identify and verify the identity of their customers, as well as, to detect, deter and report suspicious transactions that could be part of a money-laundering scheme. 6

AML & Mortgage Fraud Compliance Program v. 08.2013 ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM

AML & Mortgage Fraud Compliance Program v. 08.2013 ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM Version: 2.0 dated 08.2013 TABLE OF CONTENTS AML & Mortgage Fraud Compliance Program 1.0 PURPOSE AND SCOPE... 3 2.0 APPLICABLE REGULATIONS AND

More information

Anti-Money Laundering and Counter- Terrorism Financial Policy

Anti-Money Laundering and Counter- Terrorism Financial Policy Anti-Money Laundering and Counter- Terrorism Financial Policy Version: March 2014 1. INTRODUCTION...3 2. DEFINITIONS...3 3. RISK-BASED APPROACH...3 4. AML COMPLIANCE OFFICER...4 5. SUSPICIOUS TRANSACTION

More information

Anti-Money Laundering Policy Manual Table of Contents [Sample Client] Table of Contents

Anti-Money Laundering Policy Manual Table of Contents [Sample Client] Table of Contents Table of Contents [ Client] Table of Contents TABLE OF CONTENTS... 1 CHAPTER 1 INTRODUCTION... 3 1.1 GOALS AND OBJECTIVES... 3 1.2 REQUIRED REVIEW... 3 1.3 APPLICABILITY... 3 1.4 MONEY LAUNDERING DEFINED...

More information

Anti-Money Laundering Facts

Anti-Money Laundering Facts Anti-Money Laundering Facts Security Benefit Life Insurance Company (SBL) has implemented a formal anti-money laundering (AML) program in response to the Financial Crimes Enforcement Network s (FinCEN)

More information

Customer Identification Program - Overview

Customer Identification Program - Overview . ~ancial/~. "8 ~~. ~~~~~ ~~ ~ ~ ~ ~v ~. ~ : ~~t. Q ion CO Customer Identification Program - Overview Bank Secrecy Act / Anti-Money Laundering Examination Manual Customer Identification Program - Overview

More information

DEVELOPING AN AML (ANTI-MONEY LAUNDERING) PROGRAM:

DEVELOPING AN AML (ANTI-MONEY LAUNDERING) PROGRAM: DEVELOPING AN AML (ANTI-MONEY LAUNDERING) PROGRAM: Although the Department of the Treasury has not issued specific rules for hedge funds and hedge fund managers, hedge fund managers should adopt and implement

More information

RESIDENTIAL MORTGAGE LENDERS & ORIGINATORS L COMPLIANCE PROGRAM

RESIDENTIAL MORTGAGE LENDERS & ORIGINATORS L COMPLIANCE PROGRAM RESIDENTIAL MORTGAGE LENDERS & ORIGINATORS L COMPLIANCE PROGRAM PO Box 760 Prosper, TX 75078 972 347 9921 www.americanhfm.com Contents INTRODUCTION... 6 New FinCEN Rule 31 CFR Parts 1010 and 1029... 6

More information

Account Opening/Client Identification Program and Monitoring Client Activity

Account Opening/Client Identification Program and Monitoring Client Activity Account Opening/Client Identification Program and Monitoring Client Activity To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions

More information

Aetna Anti-Money Laundering and Financial Sanctions Compliance Policy

Aetna Anti-Money Laundering and Financial Sanctions Compliance Policy Aetna AML and Financial Sanctions Compliance Policy Aetna Anti-Money Laundering and Financial Sanctions Compliance Policy Originating Department: Aetna s AML Compliance Office Effective Date: January 1,

More information

NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186 PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM - BANKS

NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186 PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM - BANKS MAS 626 2 July 2007 Last revised on 1 July 2014 (Refer to endnotes for history of amendments) NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186 PREVENTION OF MONEY LAUNDERING AND COUNTERING

More information

TITLE 31- - Money and Finance: Treasury

TITLE 31- - Money and Finance: Treasury TITLE 31- - Money and Finance: Treasury Subtitle B- - Regulations Relating to Money and Finance Chapter X- - Financial Crimes Enforcement Network, Department of the Treasury PART 1021- - RULES FOR CASINOS

More information

MERCHANTS EXPRESS MONEY ORDER COMPANY, INC. (MEMO) AGENT ANTI-MONEY LAUNDERING COMPLIANCE GUIDE

MERCHANTS EXPRESS MONEY ORDER COMPANY, INC. (MEMO) AGENT ANTI-MONEY LAUNDERING COMPLIANCE GUIDE MERCHANTS EXPRESS MONEY ORDER COMPANY, INC. (MEMO) AGENT ANTI-MONEY LAUNDERING COMPLIANCE GUIDE Table of Contents WHY YOU AND YOUR EMPLOYEES SHOULD READ AND UNDERSTAND THIS GUIDE...1 WHY THIS GUIDE IS

More information

HIGH-RISK COUNTRIES IN AML MONITORING

HIGH-RISK COUNTRIES IN AML MONITORING HIGH-RISK COUNTRIES IN AML MONITORING ALICIA CORTEZ TABLE OF CONTENTS I. Introduction 3 II. High-Risk Countries 3 Customers 4 Products 7 Monitoring 8 Audit Considerations 8 III. Conclusion 10 IV. References

More information

Bank Secrecy Act Anti-Money Laundering Examination Manual

Bank Secrecy Act Anti-Money Laundering Examination Manual Bank Secrecy Act Anti-Money Laundering Examination Manual Core Overview - Customer Identification Program Assess the bank's compliance with the statutory and regulatory requirements for the Customer Identification

More information

NFA Regulatory Requirements. For FCMs, IBs, CPOs, and CTAs

NFA Regulatory Requirements. For FCMs, IBs, CPOs, and CTAs NFA Regulatory Requirements For FCMs, IBs, CPOs, and CTAs December 2014 Revisions: Updated to reflect the amendments to NFA Compliance Rule 2-38, CFTC Regulation 1.10, 1.11, 1.12, 1.15, 1.16, 1.55 and

More information

BSA/AML & OFAC. Volunteer Compliance Training. Agenda

BSA/AML & OFAC. Volunteer Compliance Training. Agenda Ideas + Solutions = Success BSA/AML & OFAC Ideas + Solutions = Success Volunteer Compliance Training Presented by Dorie Fitchett HCUL Regulatory Officer April 25, 2013 Agenda 1. Bank Secrecy Act (BSA)

More information

KYC, CIP, MOUSE The Patriot Act and Account Documentation

KYC, CIP, MOUSE The Patriot Act and Account Documentation Quarterly Meeting November 9, 2007 KYC, CIP, MOUSE The Patriot Act and Account Documentation Mark K. Webster, CPA, CCM Partner Treasury Alliance Group, LLC Specialists in Payments and Treasury Consulting

More information

Broker-Dealer Concepts

Broker-Dealer Concepts Broker-Dealer Concepts Broker-Dealer AML Program Checklist/Gap Analysis Published by the Broker-Dealer & Investment Management Regulation Group September 2011 I. GENERAL REQUIREMENTS AML AML Program Components

More information

Presented By Greg Baldwin

Presented By Greg Baldwin ANTI-MONEY LAUNDERING COMPLIANCE OFFICER TRAINING Presented By Greg Baldwin THE ANTI-MONEY LAUNDERING COMPLIANCE OFFICER We re going to cover: Basis for the requirement to have a Compliance Officer The

More information

The Department of the Treasury established the Financial Crimes

The Department of the Treasury established the Financial Crimes Appendix A Financial Crimes Enforcement Network Programs The Department of the Treasury established the Financial Crimes Enforcement Network in April 1990. 33 FinCEN s original mission was to establish

More information

Anti-Money Laundering Policy and Program Procedures

Anti-Money Laundering Policy and Program Procedures Anti-Money Laundering Policy and Program Procedures Dated:, 2012 Table of Contents Page I. Introduction... 1 II. Money Laundering, Terrorist Financing and Mortgage Fraud... 1 A. Money Laundering... 1 B.

More information

Practitioner s Guide for Broker-Dealers

Practitioner s Guide for Broker-Dealers Practitioner s Guide for Broker-Dealers Chapter 9: Anti-Money Laundering Authored by Betty Santangelo and Sung-Hee Suh, Schulte Roth & Zabel LLP Money laundering has generally been defined as engaging

More information

Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control

Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control Overview The Bank Secrecy Act (BSA) was created in 1970 to assist in criminal, tax, and regulatory investigations. The Financial

More information

Background. FIN-2010-G001 Issued: March 5, 2010 Subject: Guidance on Obtaining and Retaining Beneficial Ownership Information

Background. FIN-2010-G001 Issued: March 5, 2010 Subject: Guidance on Obtaining and Retaining Beneficial Ownership Information Joint Release Financial Crimes Enforcement Network Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation National Credit Union Administration Office of the Comptroller

More information

INTERNATIONAL CORRESPONDENT BANKS. Knowing Your Customer (KYC) Anti-Money Laundering Prevention of Terrorist Financing

INTERNATIONAL CORRESPONDENT BANKS. Knowing Your Customer (KYC) Anti-Money Laundering Prevention of Terrorist Financing INTERNATIONAL CORRESPONDENT BANKS Registered Name Commercial name (if applicable) Full address of the registered office of the financial institution (Street, town and country) VAT number BIC code Website:

More information

C2 Financial Corporation Anti Money Laundering Program and Suspicious Activity Reporting (AML Program)

C2 Financial Corporation Anti Money Laundering Program and Suspicious Activity Reporting (AML Program) C2 Financial Corporation Anti Money Laundering Program and Suspicious Activity Reporting (AML Program) Purpose: This program is being established and implemented by C2 Financial Corporation (C2) as an

More information

FORETHOUGHT LIFE INSURANCE COMPANY AND FORETHOUGHT NATIONAL LIFE INSURANCE COMPANY ANTI-MONEY LAUNDERING GUIDELINES FOR PRODUCERS

FORETHOUGHT LIFE INSURANCE COMPANY AND FORETHOUGHT NATIONAL LIFE INSURANCE COMPANY ANTI-MONEY LAUNDERING GUIDELINES FOR PRODUCERS FORETHOUGHT LIFE INSURANCE COMPANY AND FORETHOUGHT NATIONAL LIFE INSURANCE COMPANY ANTI-MONEY LAUNDERING GUIDELINES FOR PRODUCERS Revised July 7, 2010 Which Insurance Products Are Covered By These Guidelines?

More information

BSA/AML Program & SAR Filing Requirements

BSA/AML Program & SAR Filing Requirements BSA/AML Program & SAR Filing Requirements Iris Ikeda Catalani Commissioner of Financial Institutions Department of Commerce and Consumer Affairs Division of Financial Institutions W HAMB ~~JIO+t OfMJ=n~!Rt~

More information

MMC MORTGAGE EXAMINATION MANUAL. Bank Secrecy Act / Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements

MMC MORTGAGE EXAMINATION MANUAL. Bank Secrecy Act / Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements MMC MORTGAGE EXAMINATION MANUAL Bank Secrecy Act / Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements MULTI-STATE MORTGAGE COMMITTEE 1129 20 th Street, NW, Ninth Floor Washington,

More information

Anti-Money Laundering Program and Suspicious Activity Reporting Requirements For Insurance Companies. Frequently Asked Questions

Anti-Money Laundering Program and Suspicious Activity Reporting Requirements For Insurance Companies. Frequently Asked Questions Anti-Money Laundering Program and Suspicious Activity Reporting Requirements For Insurance Companies Frequently Asked Questions We are providing the following Frequently Asked Questions to assist insurance

More information

Unofficial translation of AML/ CFT Regulations for Banks

Unofficial translation of AML/ CFT Regulations for Banks Unofficial translation of AML/ CFT Regulations for Banks Introduction The Central Bank of Egypt (CBE) issued on 19 November 2003 AML Regulations for Banks, according to the Anti money Laundering Law No.

More information

FEDERALLY REQUIRED CUSTOMER IDENTIFICATION PROGRAM (CIP) FOR BANKS

FEDERALLY REQUIRED CUSTOMER IDENTIFICATION PROGRAM (CIP) FOR BANKS April 1, 2015 Office of Legislative Research Research Report 2015-R-0120 FEDERALLY REQUIRED CUSTOMER IDENTIFICATION PROGRAM (CIP) FOR BANKS By: Michelle Kirby, Senior Legislative Attorney APPLICABILITY

More information

Government Crime Prevention Regulations. Richard Fraher VP & Counsel to the Retail Payments Office Federal Reserve Bank of Atlanta

Government Crime Prevention Regulations. Richard Fraher VP & Counsel to the Retail Payments Office Federal Reserve Bank of Atlanta Government Crime Prevention Regulations Richard Fraher VP & Counsel to the Retail Payments Office Federal Reserve Bank of Atlanta The Big Disclaimers The views expressed in this presentation are those

More information

a GAO-02-670 GAO MONEY LAUNDERING Extent of Money Laundering through Credit Cards Is Unknown

a GAO-02-670 GAO MONEY LAUNDERING Extent of Money Laundering through Credit Cards Is Unknown GAO United States General Accounting Office Report to the Chairman, Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate July 2002 MONEY LAUNDERING Extent of Money Laundering

More information

MONEY LENDERS. Sector Specific AML/CFT Guidance Notes. May 2015

MONEY LENDERS. Sector Specific AML/CFT Guidance Notes. May 2015 MONEY LENDERS Sector Specific AML/CFT Guidance Notes May 2015 Whilst this publication has been prepared by the Financial Supervision Commission, it is not a legal document and should not be relied upon

More information

What Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies

What Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies What Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies The USA PATRIOT Act includes provisions intended to prevent the financial services

More information

RECOMMENDED CORE ELEMENTS OF AN AML TRAINING PROGRAM FOR LIFE INSURANCE AGENTS AND BROKERS

RECOMMENDED CORE ELEMENTS OF AN AML TRAINING PROGRAM FOR LIFE INSURANCE AGENTS AND BROKERS RECOMMENDED CORE ELEMENTS OF AN AML TRAINING PROGRAM FOR LIFE INSURANCE AGENTS AND BROKERS NOTICE: This document is provided to assist life insurance companies in the integration of their agents and brokers,

More information

FinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now

FinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now FinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now I. INTRODUCTION On August 25, 2015, the Financial Crimes Enforcement Network ( FinCEN ) proposed

More information

Fact Sheet for Financial Crimes Enforcement Network Geographic Targeting Orders for Manhattan, N.Y., and Miami-Dade County, Fla.

Fact Sheet for Financial Crimes Enforcement Network Geographic Targeting Orders for Manhattan, N.Y., and Miami-Dade County, Fla. Fact Sheet for Financial Crimes Enforcement Network Geographic Targeting Orders for Manhattan, N.Y., and Miami-Dade County, Fla. On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN),

More information

Identity theft. A fraud committed or attempted using the identifying information of another person without authority.

Identity theft. A fraud committed or attempted using the identifying information of another person without authority. SUBJECT: Effective Date: Policy Number: Identity Theft Prevention 08-24-11 2-105.1 Supersedes: Page Of 2-105 1 8 Responsible Authority: Vice President and General Counsel DATE OF INITIAL ADOPTION AND EFFECTIVE

More information

Treasury Department Proposes Anti-Money Laundering Regulations for Investment Advisers

Treasury Department Proposes Anti-Money Laundering Regulations for Investment Advisers CLIENT MEMORANDUM Treasury Department Proposes Anti-Money Laundering Regulations for Investment Advisers August 28, 2015 AUTHORS Benjamin J. Haskin Russell L. Smith Barbara Block On August 25, 2015, the

More information

MARSHALL UNIVERSITY BOARD OF GOVERNORS

MARSHALL UNIVERSITY BOARD OF GOVERNORS MARSHALL UNIVERSITY BOARD OF GOVERNORS Policy No. FA-12 IDENTITY THEFT PREVENTION PROGRAM 1 General Information. 1.1 Scope: To identify, detect, and respond appropriately to any Red Flags that are detected

More information

Best Practices: Anti-Money Laundering and Customer Information Selected Requirements

Best Practices: Anti-Money Laundering and Customer Information Selected Requirements Best Practices: Anti-Money Laundering and Customer Information Selected Requirements INTRODUCTION This document is intended to provide IIUSA members with guidance regarding anti-money laundering (AML),

More information

NATIONAL CREDIT UNION ADMINISTRATION OFFICE OF INSPECTOR GENERAL

NATIONAL CREDIT UNION ADMINISTRATION OFFICE OF INSPECTOR GENERAL NATIONAL CREDIT UNION ADMINISTRATION OFFICE OF INSPECTOR GENERAL OFFICE OF FOREIGN ASSET CONTROL COMPLIANCE REVIEW Report #OIG-06-09 December 18, 2006 William A. DeSarno Inspector General Released By:

More information

FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. ) ) ) ) ) ) ) )

FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. ) ) ) ) ) ) ) ) FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. In the Matter of BURKE & HERBERT BANK & TRUST COMPANY ALEXANDRIA, VIRGINIA (Insured State Nonmember Bank CONSENT ORDER FDIC-14-0103b The Federal Deposit

More information

[Billing Code: 4810-02] DEPARTMENT OF THE TREASURY. 31 CFR Part 103 RIN 1506-AA31

[Billing Code: 4810-02] DEPARTMENT OF THE TREASURY. 31 CFR Part 103 RIN 1506-AA31 [Billing Code: 4810-02] DEPARTMENT OF THE TREASURY 31 CFR Part 103 RIN 1506-AA31 Financial Crimes Enforcement Network; Customer Identification Programs for Certain Banks (Credit Unions, Private Banks and

More information

FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. CALIFORNIA DEPARTMENT OF FINANCIAL INSTITUTIONS SAN FRANCISCO, CALIFORNIA

FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. CALIFORNIA DEPARTMENT OF FINANCIAL INSTITUTIONS SAN FRANCISCO, CALIFORNIA FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. CALIFORNIA DEPARTMENT OF FINANCIAL INSTITUTIONS SAN FRANCISCO, CALIFORNIA ) ) In the Matter of ) ) CONSENT ORDER BANAMEX USA ) CENTURY CITY, CALIFORNIA

More information

AML Program. Anti-Money Laundering Program

AML Program. Anti-Money Laundering Program AML Program 1. (A) Introduction to the Broadview Mortgage Anti-Money Laundering Program 2. (B) Money Laundering and Terrorist Financing 3. (C) Anti-Money Laundering Laws and Regulatory Agencies 4. (D)

More information

Independent AML Testing of Introducing Broker- Dealers

Independent AML Testing of Introducing Broker- Dealers Independent AML Testing of Introducing Broker- Dealers Gina Storelli, CRCP, CAMS-Audit June 2014 Identify and describe a risk-based approach for independent testing of introducing broker-dealers in evaluating

More information

Financial Crimes Enforcement Network

Financial Crimes Enforcement Network Financial Crimes Enforcement Network 1 Special Due Diligence Programs for Certain Foreign Accounts Special Due Diligence Programs for Certain Foreign Accounts An Assessment of the Final Rule Implementing

More information

Green University. Identity Theft Prevention Program. Effective beginning October 31, 2008

Green University. Identity Theft Prevention Program. Effective beginning October 31, 2008 Green University Identity Theft Prevention Program Effective beginning October 31, 2008 1 I. PROGRAM ADOPTION Green University ( University ) developed this Identity Theft Prevention Program ("Program")

More information

Oklahoma State University Policy and Procedures. Red Flags Rules and Identity Theft Prevention

Oklahoma State University Policy and Procedures. Red Flags Rules and Identity Theft Prevention Oklahoma State University Policy and Procedures Rules and Identity Theft Prevention 3-0540 ADMINISTRATION & FINANCE July 2009 Introduction 1.01 Oklahoma State University developed this Identity Theft Prevention

More information

Anti-Money Laundering Issues for Securities Transfer Agents

Anti-Money Laundering Issues for Securities Transfer Agents Anti-Money Laundering Issues for Securities Transfer Agents Stanley V. Ragalevsky, Esq. Kirkpatrick & Lockhart LLP 75 State Street Boston, MA 02110 (617) 261-3100 Caveat This outline and the oral presentation

More information

NFA Regulatory Requirements. For FCMs, IBs, CPOs and CTAs

NFA Regulatory Requirements. For FCMs, IBs, CPOs and CTAs NFA Regulatory Requirements For FCMs, IBs, CPOs and CTAs June 2005 Table of Contents General Regulatory Requirements...2 Basic Records... 2 Customer Statements... 2 Customer Orders... 3 Operations and

More information

ACCOUNTANTS AND TAX ADVISORS

ACCOUNTANTS AND TAX ADVISORS ACCOUNTANTS AND TAX ADVISORS Sector Specific AML/CFT Guidance Notes May 2015 Whilst this publication has been prepared by the Financial Supervision Commission, it is not a legal document and should not

More information

Broker-Dealer Concepts

Broker-Dealer Concepts Broker-Dealer Concepts Outline of Anti-Money Laundering Obligations of Broker-Dealers Published by the Broker-Dealer & Investment Management Regulation Group September 2011 The following is a compendium

More information

[FACILITY NAME] IDENTITY THEFT PREVENTION PROGRAM. Effective May 1, 2009

[FACILITY NAME] IDENTITY THEFT PREVENTION PROGRAM. Effective May 1, 2009 [FACILITY NAME] IDENTITY THEFT PREVENTION PROGRAM Effective May 1, 2009 Because [FACILITY NAME] offers and maintains covered accounts, as defined by 16 C.F.R. Part 681 (the Regulations ), [FACILITY NAME]

More information

Client Update FinCEN Proposes Anti-Money Laundering Rules for Investment Advisers

Client Update FinCEN Proposes Anti-Money Laundering Rules for Investment Advisers 1 Client Update FinCEN Proposes Anti-Money Laundering Rules for Investment Advisers WASHINGTON, D.C. Kenneth J. Berman kjberman@debevoise.com Satish M. Kini smkini@debevoise.com Robert T. Dura rdura@debevoise.com

More information

Florida Agricultural & Mechanical University Board of Trustees Policy

Florida Agricultural & Mechanical University Board of Trustees Policy Florida Agricultural & Mechanical University Board of Trustees Policy Board of Trustees Policy Number: Date of Adoption: May 4, 2009 Date of Revision: June 6, 2013 Identity Theft Prevention Policy Subject

More information

FinCEN Issues Notice of Proposed Rulemaking that Would Extend AML Requirements to Registered Investment Advisers

FinCEN Issues Notice of Proposed Rulemaking that Would Extend AML Requirements to Registered Investment Advisers FinCEN Issues Notice of Proposed Rulemaking that Would Extend AML Requirements to Registered Investment Advisers On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US

More information

CORRUPTION. A Reference Guide and Information Note. to support the fight against Corruption. Safeguarding public sector integrity

CORRUPTION. A Reference Guide and Information Note. to support the fight against Corruption. Safeguarding public sector integrity FINANCIAL ACTION TASK FORCE CORRUPTION A Reference Guide and Information Note on the use of the FATF Recommendations to support the fight against Corruption The Financial Action Task Force (FATF) is the

More information

Identity Theft Prevention Program

Identity Theft Prevention Program Identity Theft Prevention Program DATE: 10/22/2015 VERSION 2015-1.0 Abstract Purpose of this document is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity

More information

Learn how the strength of your compliance program determines the strength of your business strategies.

Learn how the strength of your compliance program determines the strength of your business strategies. White Paper Learn how the strength of your compliance program determines the strength of your business strategies. July 2007 Risk Solutions Financial Services Introduction Following the terrorist attacks

More information

ANTI-MONEY LAUNDERING COMPLIANCE GUIDE

ANTI-MONEY LAUNDERING COMPLIANCE GUIDE LATIN AMERICA AND THE CARIBBEAN ANTI-MONEY LAUNDERING COMPLIANCE GUIDE REPORTING REQUIREMENTS RECORDKEEPING EMPLOYEE TRAINING PREVENTION OF TERRORISM FINANCING COMPLIANCE WITH LOCAL REGULATIONS COMPLIANCE

More information

FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. ) CONSENT ORDER. ) FDIC-13-0450b

FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. ) CONSENT ORDER. ) FDIC-13-0450b FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. In the Matter of THE BANK OF PRINCETON PRINCETON, NEW JERSEY (INSURED STATE NONMEMBER BANK) ) ) ) ) CONSENT ORDER ) ) ) FDIC-13-0450b ) The Federal

More information

TREASURY ADOPTS RULES REQUIRING BROKER-DEALERS TO VERIFY CUSTOMER IDENTITY

TREASURY ADOPTS RULES REQUIRING BROKER-DEALERS TO VERIFY CUSTOMER IDENTITY T O O U R F R I E N D S A N D C L I E N T S May 9, 2003 TREASURY ADOPTS RULES REQUIRING BROKER-DEALERS TO VERIFY CUSTOMER IDENTITY INTRODUCTION On April 29, 2003, the Department of Treasury ( Treasury

More information

The Amendment of the Loan Agreement (for Business)/ Overdraft Facility Agreement (for Consumption)/ Money Mortgage Agreement*

The Amendment of the Loan Agreement (for Business)/ Overdraft Facility Agreement (for Consumption)/ Money Mortgage Agreement* The Amendment of the Loan Agreement (for Business)/ Overdraft Facility Agreement (for Consumption)/ Money Mortgage Agreement* No. Clause Reference Amendment Sanctions 1. Important notice Standard Chartered

More information

ANTI-MONEY LAUNDERING FOR LENDERS

ANTI-MONEY LAUNDERING FOR LENDERS ANTI-MONEY LAUNDERING FOR LENDERS Ari Karen Offit Kurman akaren@offitkurman.com 240.507.1740 Bill Heyman Offit Kurman wheyman@offitkurman.com 301.575.0393 THE RATIONALE FOR THE NEW REGULATIONS The Financial

More information

Texas A&M International University Identity Theft Prevention Program

Texas A&M International University Identity Theft Prevention Program Texas A&M International University Identity Theft Prevention Program 1 I. PROGRAM ADOPTION Texas A&M International University ( University ) developed this Identity Theft Prevention Program ( Program )

More information

Wolfsberg Anti-Money Laundering Principles for Correspondent Banking

Wolfsberg Anti-Money Laundering Principles for Correspondent Banking Wolfsberg Anti-Money Laundering Principles for Correspondent Banking 1 Preamble The Wolfsberg Group of International Financial Institutions 1 has agreed that these Principles constitute global guidance

More information

The Florida A&M University. Identity Theft Prevention Program. Effective May 1, 2009

The Florida A&M University. Identity Theft Prevention Program. Effective May 1, 2009 The Florida A&M University Identity Theft Prevention Program Effective May 1, 2009 I. PROGRAM ADOPTION This Identity Theft Prevention Program ("Program") is established pursuant to the Federal Trade Commission's

More information

8 Guiding Principles for Anti-Money Laundering Polciies and Procedures in

8 Guiding Principles for Anti-Money Laundering Polciies and Procedures in TCH Guiding Principles September 2014 Exposure Draft Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking Exposure Draft for Public Comment 2 Preamble to the Exposure

More information

New Customer Identification Procedure Rules for Brokers and Dealers Take Effect

New Customer Identification Procedure Rules for Brokers and Dealers Take Effect Client Publication October 2003 New Customer Identification Procedure Rules for Brokers and Dealers Take Effect I. INTRODUCTION Origins of the CIP Rule On April 30, 2003, the U.S. Department of the Treasury

More information

ANTI-MONEY LAUNDERING COURSE

ANTI-MONEY LAUNDERING COURSE ANTI-MONEY LAUNDERING COURSE COPYRIGHT 2011 SUCCESS CONTINUING EDUCATION 2 Corporate Plaza Drive, Suite 100 Newport Beach, CA 92660 (949) 706-9425 (A member of the Success CE family of Companies.) Copyright

More information

FAQs: Final CIP Rule

FAQs: Final CIP Rule Financial Crimes Enforcement Network Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation National Credit Union Administration Office of the Comptroller of the Currency

More information

Regulatory Compliance and Trade

Regulatory Compliance and Trade Regulatory Compliance and Trade Global Transaction Services Cash Management Trade Services and Finance Securities Services Fund Services Regulatory Compliance and Trade 2007 These materials are provided

More information

Nevada Registered Agents Association

Nevada Registered Agents Association Nevada Registered Agents Association Best Practices Recommendations to Prevent the Exploitation of Nevada Business Entities for Criminal Activities, and for the Protection of the Nevada Registered Agent

More information

The 2006 FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual:

The 2006 FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual: The 2006 FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual: Knowing the Risks Is It Possible to Keep Pace and Manage Them All? By: Carmina Hughes, Executive Director and Patricia McKeown,

More information

Central Oregon Community College. Identity Theft Prevention Program

Central Oregon Community College. Identity Theft Prevention Program Central Oregon Community College Identity Theft Prevention Program Effective beginning May 1, 2009 I. PROGRAM ADOPTION This program has been created to put COCC in compliance with Section 41.90 under the

More information

BANK SECRECY ACT POLICY

BANK SECRECY ACT POLICY BANK SECRECY ACT POLICY Policy Statement In compliance with section 748.2 of the NCUA Rules and Regulations, the board of directors of Alternatives Federal Credit Union (AFCU) has adopted the following

More information

REPUBLIC OF ARMENIA LAW ON COMBATING MONEY LAUNDERING AND TERRORISM FINANCING

REPUBLIC OF ARMENIA LAW ON COMBATING MONEY LAUNDERING AND TERRORISM FINANCING REPUBLIC OF ARMENIA LAW ON COMBATING MONEY LAUNDERING AND TERRORISM FINANCING CHAPTER 1 GENERAL PROVISIONS The purpose of this Law shall be protecting the rights, freedoms, and legitimate interests of

More information

SUMMARY: This Interpretive Release sets forth an interpretation of the regulation

SUMMARY: This Interpretive Release sets forth an interpretation of the regulation [Billing Code 4810-02-P] United States Department of Treasury Financial Crimes Enforcement Network 31 CFR Part 103 Interpretive Release 2004-1 Anti-Money Laundering Program Requirements For Money Services

More information

SAMPLEBANK CUSTOMER IDENTIFICATION PROCEDURES

SAMPLEBANK CUSTOMER IDENTIFICATION PROCEDURES It is the policy of SampleBank to determine and verify the identity of all of its customers in compliance with Section 326 of USA PATRIOT Act and Part 103.121 of the regulations under the Bank Secrecy

More information

THE FORTY RECOMMENDATIONS OF THE FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING

THE FORTY RECOMMENDATIONS OF THE FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING THE FORTY RECOMMENDATIONS OF THE FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING 1990 A. GENERAL FRAMEWORK OF THE RECOMMENDATIONS 1. Each country should, without further delay, take steps to fully implement

More information

01.230 IDENTITY THEFT PREVENTION PROGRAM (RED FLAGS)

01.230 IDENTITY THEFT PREVENTION PROGRAM (RED FLAGS) 01.230 IDENTITY THEFT PREVENTION PROGRAM (RED FLAGS) Authority: Board of Trustees History: Effective May 1, 2009 (approved initially April 24, 2009) Source of Authority: Related Links: Responsible Office:

More information

MEMORANDUM. FinCEN Rule on AML Program and SAR Requirements for Residential Mortgage Lenders and Originators

MEMORANDUM. FinCEN Rule on AML Program and SAR Requirements for Residential Mortgage Lenders and Originators ATTORNEYS AT LAW Marc J. Lifset mlifset@mcglinchey.com (518) 432-8335 (direct voice) (518) 432-7290 (direct fax) FLORIDA LOUISIANA MISSISSIPPI NEW YORK OHIO TEXAS To: From: Friends and Clients Philip Bohi

More information

The Newest AML Deputy in Town: FinCEN s Geographic Targeting Orders Put the Bull s-eye on the Title Insurance Industry. By Kevin L.

The Newest AML Deputy in Town: FinCEN s Geographic Targeting Orders Put the Bull s-eye on the Title Insurance Industry. By Kevin L. The Newest AML Deputy in Town: FinCEN s Geographic Targeting Orders Put the Bull s-eye on the Title Insurance Industry By Kevin L. Shepherd 1 The Federal Government s effort to combat money laundering

More information

Florida International University. Identity Theft Prevention Program. Effective beginning August 1, 2009

Florida International University. Identity Theft Prevention Program. Effective beginning August 1, 2009 Florida International University Identity Theft Prevention Program Effective beginning August 1, 2009 I. PROGRAM ADOPTION Florida International University developed this Identity Theft Prevention Program

More information

Bank Secrecy Act/ Anti-Money Laundering Examination Manual

Bank Secrecy Act/ Anti-Money Laundering Examination Manual Bank Secrecy Act/ Anti-Money Laundering Examination Manual Federal Financial Institutions Examination Council Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National

More information

STEPTOE & JOHNSON LLP

STEPTOE & JOHNSON LLP STEPTOE & JOHNSON LLP The USA PATRIOT Act and Financial Institutions Who does it cover? What does it require? And what does it mean for your Company? On October 26, 2001, in the wake of the September 11

More information

I. Purpose. Definition. a. Identity Theft - a fraud committed or attempted using the identifying information of another person without authority.

I. Purpose. Definition. a. Identity Theft - a fraud committed or attempted using the identifying information of another person without authority. Procedure 3.6: Rule (Identity Theft Prevention) Volume 3: Office of Business & Finance Managing Office: Office of Business & Finance Effective Date: December 2, 2014 I. Purpose In 2007, the Federal Trade

More information

Texas A&M University Commerce. Identity Theft Prevention Program Effective beginning May 1, 2009

Texas A&M University Commerce. Identity Theft Prevention Program Effective beginning May 1, 2009 Texas A&M University Commerce Identity Theft Prevention Program Effective beginning May 1, 2009 1 I. PROGRAM ADOPTION Texas A&M University - Commerce ( University ) developed this Identity Theft Prevention

More information

UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ASSESSMENT OF CIVIL MONEY PENALTY

UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ASSESSMENT OF CIVIL MONEY PENALTY UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK IN THE MATTER OF: ) ) Number 2015-01 Oppenheimer & Co., Inc. ) New York, NY ) ASSESSMENT OF CIVIL MONEY PENALTY

More information

OFAC Office of Foreign Assets Control

OFAC Office of Foreign Assets Control OFAC Office of Foreign Assets Control What is it? The Office of Foreign Assets Control ( OFAC ) of the US Department of the Treasury is a law enforcement agency, not a regulatory agency. OFAC administers

More information

FINANCING OF TERRORISM THROUGH NON PROFIT ORGANIZATIONS

FINANCING OF TERRORISM THROUGH NON PROFIT ORGANIZATIONS CENTRAL BANK OF THE REPUBLIC OF ARMENIA FINANCIAL MONITORING CENTER APPROVED BY THE DECISION OF THE GOVERNOR OF THE CENTRAL BANK OF ARMENIA NO 1/1218A FROM 11.12.2014 ANNEX FINANCING OF TERRORISM THROUGH

More information

Written Supervisory Procedures ( WSP ) Review Checklist for Proprietary Trading Firms

Written Supervisory Procedures ( WSP ) Review Checklist for Proprietary Trading Firms Written y Procedures ( WSP ) Review Checklist for Proprietary Trading Firms This WSP Checklist is an outline of selected key topics representative of the range of business activities typically proposed

More information

FACTA Identity Theft Red Flags Program. www.chs.acfei.com

FACTA Identity Theft Red Flags Program. www.chs.acfei.com 1 FACTA Identity Theft Red Flags Program Module 1 Fair and Accurate Credit Transactions Act Overview Identity thieves use individual s personal identifiable information to open new accounts and misuse

More information

Anti-Money Laundering Policy Manual (BSA/AML/SAR)

Anti-Money Laundering Policy Manual (BSA/AML/SAR) ANTI-MONEY LAUNDERING POLICY MANUAL Last Updated November 2013 Section 1 Introduction... 4 1.1 Goals & Objectives... 4 1.2 Money Laundering Defined... 4 1.3 Board Oversight... 5 1.4 Security Officer Designation...

More information

Bank Secrecy Act for Directors. Barb Boyd Content Manager CU Solutions Group

Bank Secrecy Act for Directors. Barb Boyd Content Manager CU Solutions Group Bank Secrecy Act for Directors Barb Boyd Content Manager CU Solutions Group Agenda What is the Bank Secrecy Act? How to have a successful BSA Compliance Program OFAC responsibilities. Penalties for non-compliance.

More information

ACCG Identity Theft Prevention Program. ACCG 50 Hurt Plaza, Suite 1000 Atlanta, Georgia 30303 (404)522-5022 (404)525-2477 www.accg.

ACCG Identity Theft Prevention Program. ACCG 50 Hurt Plaza, Suite 1000 Atlanta, Georgia 30303 (404)522-5022 (404)525-2477 www.accg. ACCG Identity Theft Prevention Program ACCG 50 Hurt Plaza, Suite 1000 Atlanta, Georgia 30303 (404)522-5022 (404)525-2477 www.accg.org July 2009 Contents Summary of ACCG Identity Theft Prevention Program...

More information