There are four elements of an AML Compliance Program for Non-Bank Residential Mortgage Lenders and Originators (RMLOs):
• Development of internal policies, procedures and controls
• Designation of an AML Compliance Officer at your firm
• Ongoing employee training program
• Independent audit conducted annually to test your AML program
Development of Internal Policies, Procedures and Controls
Every firm must have a written AML Policy and Procedure Statement. This Statement must cover your firm's internal policies, procedures, and controls in place to prevent potential money laundering activities. This Statement should also provide information about what the firm and their employees need to do if money laundering is suspected, as well as the consequences if an employee does not follow the firm's AML policy. The Policy and Procedures Statement also designates which senior manager(s) at the firm is the AML Compliance Officer, and which senior manager will be responsible for written approval of the firm's AML program.
Most large firms have a written Policy and Procedure document in place already. While your firm should have a plan which is customized for your business, we have a prototype Policy and Procedures as an example. (COMING SOON)
Designation of a Compliance Officer
At least one person must be designated as the "AML Compliance Officer," and who has the responsibility to oversee your firm's AML program. This person should have the authority to ensure that your firm meets all federal and regulatory requirements.
Ongoing Employee Training Program
All RMLOs must provide ongoing education and training programs on at least an annual basis. The training must cover your firm's policies and procedures, and relevant federal laws and regulatory AML requirements. Records should be maintained to provide evidence that such training was accomplished.
An AML training program for RMLOs is available immediately through our training partner, Exchange Analytics Inc. Exchange Analytics provides training to most of the world's largest financial firms. To access the AML training for RMLOs, please click here.
Independent Audit to Test AML Program
RMLOs must conduct annual testing of their AML compliance program, which is commonly referred to as an AML audit. This annual AML audit may be done by a firm's personnel (e.g. internal audit staff) who are independent of the areas that are exposed to potential money laundering risks, or by engaging an outside party with experience in this type of audit (e.g. EA Compliance). The results of the audit should be documented and reported to the firm's senior management or internal audit committee. Please click here to get more information about our audit services.