Frequently Asked Questions
What goes into an independent review?
An AML Compliance Services BSA/AML review generally includes the following:
A full review of your company's BSA/AML compliance program manual
Testing of your BSA/AML policies and procedures
Customer Identification Procedure (CIP) review
Transactional testing and evaluation
OFAC and other Specially Designated Nationals (SDN) watch list search procedures
Recordkeeping and record retention procedures
FINCEN-related filings review (CTRs and SARs)
Evaluation of AML training programs
Evaluation of automated monitoring systems and management information systems
Review of past audit reports to assess the efficacy of recommended implemented changes
Adequacy of AML risk-assessment procedures of the BSA/AML program
Why use AML Compliance Services rather than my regular auditors or accountants?
Since AML Compliance Services is a company specifically dedicated to BSA/AML compliance, we can provide these services in a more efficient and cost-effective manner than other companies or firms not focused in this specific area. While some auditors or accountants offer these services, these professionals typically don't have the expertise to perform your review as cost effectively as someone who specializes in this area. As a certified ACAMS (Association of Certified Anti-Money Laundering Specialists) specialist in BSA/AML compliance, AML Compliance Services can give you as well as regulatory authorities a higher degree of confidence that you have met your BSA/AML compliance requirements.
My bank says I need an independent review ASAP--do you offer expedited services?
Yes. Please call for a quote.
Do you conduct reviews in other states ?
Yes, though we are based in Chicago, AMLCS has conducted reviews in IL, CA, NY, IN, WI, FL, AZ, NM, MN, CO, GA, MA, NJ, TX, MD and IA.
How often does my company need to perform an independent BSA/AML review?
Requirements for conducting independent BSA/AML reviews are different from industry to industry. Most Securities broker dealers, Futures Commission Merchants (FCMs), or introducing brokers (IBs) are obligated by The Financial Industry Regulatory Authority, Inc. (FINRA) or National Futures Association (NFA) to conduct reviews on at least an annual basis while the Bank Secrecy Act implies that most money services businesses (MSBs), precious metal/jewelry dealers, or non-bank residential mortgage lenders and originators (RMLOs) should conduct independent reviews on a periodic basis. However, unless an AML compliance program is deemed highly effective at combating money laundering, annual independent BSA/AML reviews would be strongly recommended.
How much will my BSA/AML review cost?
As each review’s parameters are specific to each company, there is no standard charge for an BSA/AML compliance review. However, it is our primary objective to provide the client with the most cost-effective independent AML compliance review as possible. Our fees are lower compared to larger firms because our services are specialized. Please feel free to contact AML Compliance Services for a free consultation and quote.
What are my Company's BSA/AML requirements?
Title III, Section 352(a) of the USA PATRIOT Act of 2001 amended the Bank Secrecy Act of 1970 (BSA) to require that financial institutions establish an AML program, including at a minimum:
A. The development of internal policies, procedures and controls;
B. The designation of a qualified compliance officer;
C. An ongoing employee training program; and
D. An independent audit function to test the program.
If you are in a regulated business which is required to establish and maintain an BSA/AML compliance program, AML Compliance Services can assist you with any of the above AML requirements. Although we do not provide employee training courses, AML Compliance Services can refer you to highly credible compliance companies that can provide you with useful employee training, regardless of the AML-related industry you come from.