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President • AML Audit Services
Best Practices:
- Develop a written risk assessment.
- Develop a risk-based AML compliance program of policies, procedures and internal controls tailored to the RMLO.
- Monitor transactions across all products and services to meet regulatory requirements and identify suspicious activity.
- Provide training to personnel with access to transactions, customers, compliance operations or activity that may be exploited by criminals.
- Conduct independent testing by a qualified professional, as required for RMLOs on a periodic basis.
- Ensure accuracy and timely reporting for Form 8300 and Suspicious Activity Reports (SARs).
- Know your reliance relationships.
President • AML Audit Services
Best Practices:
- Develop a written risk assessment.
- Develop and maintain effective, risk-based AML policies and procedures approved by senior management and/or the board of directors.
- Monitor transactions to ensure regulatory reporting requirements are met and to identify any suspicious activity.
- Provide training to personnel with access to transactions, customers, compliance operations or activity that may be exploited by criminals.
- Independent testing by a qualified professional is required for precious gems dealers on a periodic basis.
- Appoint an experienced and knowledgeable AML compliance officer.
- Ensure accuracy and timely reporting for Form 8300.
Officer-in-Charge • Royal Canadian Mounted Police
Best Practices:
- Develop a comprehensive risk review appropriate to the organization.
- Create a culture of compliance.
- Develop engaging, interactive training programs using real-life examples.
- Look to the outside for a chief anti-money laundering officer to oversee compliance programs.
- Use outside experts for program and systems reviews.
- Integrate AML and fraud solutions.
- Secure your data.
President • AML Audit Services
Best Practices:
- Produce a written AML risk assessment.
- Develop and maintain effective, risk-based AML policies, procedures and internal controls.
- Monitor transactions across all products and services to ensure regulatory reporting requirements are met and to identify any suspicious activity.
- Provide training to personnel with access to transactions, customers, compliance operations or activity that may be exploited by criminals.
- Know your reliance relationships.
- Independent testing by a qualified professional is required for broker-dealers on an annual basis.
- Conduct periodic self-testing to evaluate adequacy of AML controls.
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