Deadline is Coming for Anti-Money Laundering Programs

Residential Mortgage Brokers and Originators must know that the deadline for Anti-Money Laundering Program Compliance is August 13th.

The Financial Crimes Enforcement Network (FinCEN) announced that non-bank residential mortgage lenders and originators must implement anti-money laundering (AML) programs by August 13, 2012.

The AML programs must be reasonably designed to prevent residential mortgage brokers and originators from being used to facilitate money laundering or finance terrorist activities.

Non-bank residential mortgage lenders and originators include “mortgage companies” and “mortgage brokers.”

AML Programs must include:

Policies, procedures and internal controls based upon mortgage companies and broker assessment of money laundering and terrorist financing risks associated with its products and services and shall include:

  • Provisions for third-party testing to monitor and maintain adequate compliance of the AML program;
  • Provisions for ongoing training of appropriate personnel regarding the responsibilities under the AML program;
  • The designation of a compliance officer, responsible for implementing and updating the AML program.  (The compliance officer shall supervise the training of appropriate personnel for the AML program.)
  • The AML program must be approved by senior management.

A copy of the AML program must be available for inspection by FinCEN or its designee upon request.

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