Anti Money Laundering Policy - with SAR Reporting Matrix
If your company already has an "industry standard red flag fraud prevention plan" in place, you likely meet 95% of the requirements of the Anti-Money Laundering rules promulgated by FinCen. The requirement effective July, 2012 requires many companies not previously required to report suspicious activity, such as fraud or certain cash-related activities, to have a program in place for reporting (SARs Reporting). This plan meets this requirement, but should be incorporated with your company's general fraud prevention program (Red Flags).
Here is the FINCEN Rule. Here is a FREE RESOURCE - Suspicious Activity Reporting for Dummies |
With FinCen's determination that mortgage firms are money businesses, we must now comply with the AML and SAR rules. Since the industry already performs a high level of fraud detection and prevention, this plan is designed to extend those functions so that the Quality Control Plan addresses FinCen rules as well. Plug this plan in to your Quality Control plan for a full-featured fraud detection, prevention and reporting process.
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