If you do not review your Anti-Money Laundering Program (Program) for updates, as needed, and at least annually, you are not complying with Bank Secrecy Act (BSA) guidelines. You are violating the applicable statute if you are not conducting an Anti-Money Laundering (AML) test annually but no later than eighteen months from the previous test.
If you are not implementing AML training annually, including, when needed, for new hires, you have caused a statutory violation.
And, if you do not have a responsible, designated, and ratified AML Officer, you have not complied with the BSA mandates.
We keep a record of evolving money laundering schemes. At this point, our due diligence auditors avail themselves of an extensive database that keeps us alert to the nefarious money laundering tactics the crooks have developed and, unfortunately, continue to develop.
I will provide several actions and non-actions – what some organizations do or don't do – that trigger regulatory violations. My focus is on RMLOs.
