Anti Money Laundering, AML/ CFT Manual is mandatory for each Money Service Business in the USA and Worldwide. Ask an expert Crypto Lawyer at +919888861666
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Anti Money laundering Policy and Procedure Manual – AML – MSB – SEC
DRAFT OF POLICY HEADLINES:- Before filing an application for registration with BSA and Money Service Business License, you need to prepare a detailed Anti Money Laundering Policies & Procedures Manual.
1. INTRODUCTION/ POLICY STATEMENT:
XYZ Inc.’s priorities are to take necessary steps to restrict (1) corruption; (2) cybercrime, including relevant cyber security and virtual currency considerations; (3) foreign and domestic terrorist financing; (4) fraud; (5) transnational criminal organization activity; (6) drug trafficking organization activity; (7) human trafficking and human smuggling; (8) restriction on cash and suspicious transactions; and (9) proliferation financing and reporting incidents to FinCEN and other appropriate Federal and State Regulators.
2. POLICY AND PROCEDURE: ANTIMONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM:
3. UNDERSTANDING GLOBAL KYC:
4. POLICY AND PROCEDURE: COMPLIANCE OFFICER AND HIS DUTIES:
5. POLICY AND PROCEDURE: SHARING AML INFORMATION WITH FEDERAL LAW ENFORCEMENT AGENCIES AND OTHER FINANCIAL INSTITUTIONS:
6. POLICY AND PROCEDURE: CHECKING THE OFFICE OF FOREIGN ASSETS CONTROL LISTINGS:
7. POLICY AND PROCEDURE: CUSTOMER IDENTIFICATION PROGRAM:
7.1 General:
7.1.1. Client/Freelancer/Agency/Platform User Identification Procedures for Natural Persons;
7.1.2. Client/Freelancer/Agency/Platform User Identification Procedures for Corporations, Trusts, and other Legal Entities;
7.1.3. High-Risk Client/Freelancer/Agency/Platform Users;
7.1.4. Enhanced User Identification Procedural norms for ‘High-Risk’ Natural Persons;
OTHER IDENTIFICATION/VERIFICATION STEPS:
7.2 Customers Who Refuse to Provide Information:
7.3 Verifying Information:
7.4 Lack of Verification:
7.5 Recordkeeping:
7.6 Comparison with Government-Provided Lists of Terrorists:
7.7 Notice to Customers:
7.8 Reliance on Other Financial Institutions for Identity Verification:
8. POLICY AND PROCEDURE: CUSTOMER DUE DILIGENCE RULE:
9. CORRESPONDENT ACCOUNTS FOR FOREIGN SHELL BANKS:
10. DUE DILIGENCE AND ENHANCED DUE DILIGENCE REQUIREMENTS FOR CORRESPONDENT ACCOUNTS OF FOREIGN FINANCIAL INSTITUTIONS
11. DUE DILIGENCE AND ENHANCED DUE DILIGENCE REQUIREMENTS FOR PRIVATE BANKING ACCOUNTS/SENIOR FOREIGN POLITICAL FIGURES
12. COMPLIANCE WITH FinCEN’s ISSUANCE OF SPECIAL MEASURES AGAINST FOREIGN JURISDICTIONS, FINANCIAL INSTITUTIONS OR INTERNATIONAL TRANSACTIONS OF PRIMARY MONEY LAUNDERING CONCERN:
13. POLICY AND PROCEDURE: MONITORING ACCOUNTS FOR SUSPICIOUS ACTIVITY:
13.1 Emergency Notification to Law Enforcement by Telephone:
13.1.1. Detecting Red Flags
13.1.2.Responding to Suspicious Activity and Red Flags:
13.1.3.Stopping/continuing work on suspicion of any such activity:
14. POLICY AND PROCEDURE: SUSPICIOUS TRANSACTIONS AND BSA REPORTING:
14.1 Filing a Form No. FinCEN 111 about SAR:
14.2 Currency Transaction Reports (CTR) – $10,000 Threshold:
15. POLICY AND PROCEDURE: AML RECORDKEEPING AND SUSPICIOUS ACTIVITY REPORT (SAR):
15.1 Responsibility for maintaining required records and filing SARs:
15.2 SAR Maintenance and Confidentiality:
15.3 Additional Records:
16. POLICY AND PROCEDURE: BANK/XYZ INC. RELATIONSHIP – FINCEN, FINRA, BSA COMPLIANCE & E-FILING:
17. POLICY AND PROCEDURE: TRAINING PROGRAMS:
19. POLICY AND PROCEDURE: MONITORING EMPLOYEE CONDUCT AND ACCOUNTS:
20. POLICY AND PROCEDURE: CONFIDENTIAL REPORTING OF AML NON-COMPLIANCE:
21. POLICY AND PROCEDURE: ADDITIONAL RISK AREAS:
22. CEO, SENIOR MANAGER, AND/OR BOARD APPROVAL:
This is a basic draft policy and procedure of the Manual. For a detailed Policy and Procedure Manual Call a Crypto lawyer at +91 9888861666 or +919815280500
