Anti-Money Laundering Program
Preparation is Protection 
Article - Excerpts
Monitoring Suspicious Activity
SAR Narrative




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You may be interested in reading my magazine article:Back
Anti-Money Laundering Program
    Preparation is Protection 
It is published in the National Mortgage Professional Magazine. (Free Subscription to our Clients and Subscribers.)

I have provided excerpts from the article and the download link.

The compliance effective date to implement an Anti-Money Laundering Program, pursuant to the Final Rule promulgated by FinCEN, is August 13, 2012. This article outlines the basics to drafting the policy and procedures.

I hope you enjoy this article.

Please feel free to contact us at any time.

Jonathan Foxx
President and Managing Director 
Monitoring Suspicious Activity
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The RMLO's management must institute procedures which are designed to detect money laundering. Management should identify high-risk accounts in the company's loan production or portfolio, by using various methodologies, such as accessing a federal banking agency's list, a GSE exclusionary list, or other lists of prohibited and restricted parties. In particular, management should enable AML due diligence procedures relating to customers who apply for a mortgage loan product.

The AML Program is intended to cover initial purchase money loans and traditional refinancing transactions facilitated or originated by RMLOs. Furthermore, FinCEN expects that RMLOs participating in transactions involving funds or programs under the Troubled Asset Relief Program and similar federal programs, or a state housing authority or housing assistance program, will follow the AML Program and file SARs to the extent that any transactions conducted by the RMLO could reasonably be considered to be extending a residential mortgage loan or offering or negotiating the terms of a residential mortgage loan.
SAR Narrative - "The 5 Ws"

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If I were to choose the central feature of the SAR, I would select the SAR narrative.

Each SAR requires a narrative to be provided by the SAR filer.

Over time, my firm has compiled numerous examples of common patterns of suspicious activities from our audit and due diligence reviews. Based on our experience, we believe that there are five interrogative categories to be considered when writing a SAR narrative: who? what? when? where? and why?

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