FAQ:

What are my firm’s AML requirements?
For NASD registered firms, you may view the NASD requirements at www.nasd.org. For NFA registered firms, you may view the NFA requirements at www.nfa.futures.org
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What is involved in an AML performance audit?

An AML performance audit involves the following steps:

  1. Examination of a firm’s AML Policy & Procedures Statement.
  2. Examination of a firm’s AML internal controls.
  3. Examination of a firm’s AML program and procedures for the various components within the firm’s AML program.
  4. Examination of the firm’s CIP (Client Identification Program) including a test of new clients against lists published by the US Treasury related to SDNs (Specially Designated Nationals), blocked persons and non-cooperative countries and territories.
  5. An exist meeting with the firm’s compliance officer(s) to discuss various aspects concerning the firm and its AML program.

After the audit is completed, the results are assembled and summarized in a report form to be presented to the firm’s compliance officer and/or audit committees.
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Why use an outside party for my AML performance audit?
An AML audit may be conducted by members of your firm’s staff who are independent of any areas that are exposed to potential money laundering risks, or by an outside party. Many smaller firms do not have employees who are independent of these areas. Other firms find it costly to devote the time and resources necessary to accomplish this internally. Finally a firm may wish to consider the appearance of having an audit performed by an independent party, which helps eliminate questions of conflicts of interest that may arise when using in-house staff. For these reasons most firms use independent third parties to provide this service.
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Why use EA Compliance rather than my regular auditors or accountants?
In all probability we can provide these services in a more efficient and cost-effect manner than someone who is not focused in this specific area. While some auditors or accountants offer these services, these types of professionals typically don’t have the expertise to perform your audit as cost effectively as someone who specializes in this area. Specialists in this area can also give both you and regulatory authorities a higher degree of confidence that you have met your AML compliance requirements.
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How much does the AML audit cost?
Given that every financial institution is unique, there is no standard charge for an AML performance audit, however EA Compliance strives to be extremely cost effective and value oriented. Please feel free to call us for a quote, or drop us an email and we’ll call you.
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How much does the AML training cost?
The online AML training course is only $35 per person. This includes everything – the course itself, Certificate of Completion, and third party record keeping so that you can absolutely prove that your employees took this training.
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How often do I have to do an AML audit and provide AML training?
Generally the AML audit and employee training must be performed annually.
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Does my firm have to provide AML training for my employees?
It is the firm’s responsibility to insure that their appropriate staff is in compliance with the annual training requirement.
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What will my firm need to provide to prove compliance to a regulatory body?
To prove an AML audit has performed, EA Compliance furnishes a letter attesting that the audit was performed, including how the audit was performed along with an opinion regarding your firm’s compliance as required under the USA PATRIOT Act.
To prove satisfaction of annual training requirements, Exchange Analytics provides a Certificate of Completion attesting that your employee completed the training. This along with acknowledgement from your employees that they have read your Policy and Procedures statement should be provided to regulators.
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Do I have to keep records showing compliance?
Records showing compliance must be retained for a minimum of 5 years. All records pertaining to your Customer Identification Procedures must be kept for a minimum of 5 years after an account is closed.
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Why should I use EA Compliance as my AML auditor?
EA Compliance is focused primarily on providing this function. Our staff is uniquely qualified to assist your firm in complying with the various requirements under the USA PATRIOT Act. In our opinion, no other company offers the experience and training to best serve your firm in this area in a cost effective manner.
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Why should I use Exchange Analytics as my AML training provider?
Exchange Analytics’ online AML training course is immediately available, very convenient and cost-effective, and most importantly does an excellent job in reminding your employees of their obligations under the Patriot Act pertaining to the prevention of potential money laundering. Exchange Analytics is the world’s largest provider of compliance programs to the derivatives industry, and the majority of the world’s largest financial services firms use their courses.
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How do I access Exchange Analytics’ AML Training Course?
Just go to www.xanalytics.com/amltraining and you’ll begin a short registration process. You can access the course by inputting a credit card for the $35 charge. If you prefer you may call us for an access code at 800-823-8442. If you have a number of employees to register, please call us at 800-823-8442 or email us at exch@xanalytics.com .
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