Conducting the test of the Anti-Money Laundering Program is statutorily required. Each Residential Mortgage Lender and Originator ("RMLO") must adopt a policy and procedure for Anti-Money Laundering in recognition of its obligations under the Bank Secrecy Act ("BSA"), other related money laundering regulations, the requirements of the Financial Crimes Enforcement Network (FinCEN), and federal and state licensing agencies.
Testing every twelve months is recommended but not later than every eighteen months. An audit of the procedures must be conducted either internally, pursuant to FinCEN guidelines, or by an independent, external auditor entirely independent of the BSA Officer. Most clients retain us to conduct the audit test every twelve months. Our firm was the first in the country to offer AML testing for RMLOs.
You can request information about our AML policy, testing, and training HERE.
Simply stated, fraud creates value for the fraudster. Money laundering is the process by which that value enters the financial system and then moves around within and exits the financial system.
