1. Anti-Money Laundering Program a. An AML program must be in writing and include, at a minimum; i. Policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act (BSA) and its implementing rules; ii. Policies and procedures that can be reasonably expected to detect and cause the reporting of transactions under 31 U.S.C. 5318(g) and the implementing regulations thereunder; iii. The designation of an AML compliance officer (AML Officer), including notification to the SROs; Ongoing AML employee training; and iv. An independent test of the firm s AML program, annually for most firms. If we can be of assistance in the anti-money laundering arena, please contact us to discuss how we can be helpful.
|