Have You Implemented an AML Compliance Program?
The Patriot Act, passed In October 2001, amended the Bank Secrecy Act (BSA) to require businesses defined as financial institutions to implement an anti-money laundering (AML) compliance program.
Entities subject to AML program requirements include: banks and other depository institutions (such as credit unions); securities broker dealers; casinos; money services businesses; mutual funds; operators of credit card systems; dealers in precious metals, precious stones, and jewels; and the insurance industry.
FinCEN, the Financial Crimes Enforcement Network,
a bureau of the U.S. Treasury Department, issued final regulations to require that all Money Services Businesses (MSBs)
have an effective AML compliance program. Each MSB’s AML compliance program must be in writing and designed to prevent the MSB from being used to facilitate money laundering and the financing of terrorist activities. An MSB’s AML program must be commensurate with the risks posed by the location, size, nature, and volume of the financial services provided by the MSB.
Compliance assists in protecting MSBs from charges of complicity in criminal activities and from criminal penalties for noncompliance, both of which could seriously damage a company’s reputation if left unchecked.