AML Independent Reviews - What are the requirements?

Hand holding magnifying glass over paper zoomed in on “AML Program Review” text.

“Section 352 of the USA PATRIOT ACT amended the Bank Secrecy Act (BSA) to require financial institutions, including broker-dealers, to establish AML programs.”  Source: www.sec.gov

AML programs are built on the foundation of a risk assessment and must include, but are not limited to:

  1. a compliance officer – responsible to ensure that the company is AML compliant,

  2. written policies, procedures, and controls – to detect, prevent, limit, and control money laundering and financial risk,

  3. independent reviews – to measure the program’s efficiency and correct problems, and

  4. training – ongoing to maintain compliance with regulations.

These requirements are also known as the four pillars of BSA/AML programs and include all the steps taken to fight money laundering and financial crimes.

What can Currin Compliance Services do for you?

Life insurance companies must periodically conduct an independent review as a foundation of AML and OFAC programs. In today’s environment, there is no room for error. Regulators have cited companies whose independent review is inadequate.

What is “adequate” for your AML audit? And how much is enough?

We know what is “adequate” and how to test your processes and data—and how to evaluate your controls’ effectiveness. Our comprehensive and detailed independent review (either in-person or virtually) will leave you with a road map to those areas that may need attention.

If you are struggling or have questions, we’re only a phone call away. Our Certified Anti-Money Laundering Specialist (CAMS), Mandy Bain, knows every question is important and has the expertise and patience to answer them.

For more information or to schedule a meeting, send us an email.

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AML Independent Reviews in the Virtual World

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Drafting Policies and Procedures — Why is a risk assessment important?