Money laundering is a huge problem for financial institutions and monitoring compliance and reporting is a challenge. As I read through FinCEN’s recent announcement, it became clear…the law is not really clear! Because real estate transactions are large in dollars, they are one of the easiest places to “clean up the money.” If you think Anti-Money Laundering regulations are vague or too complicated, now is your chance to help clarify how current regulations may be …
FINRA Regulatory Notice 18-19 issued May 11, 2018 expands AML Program requirements to include additional risk-based procedures, or the “fifth pillar” required for AML programs under the new FinCEN CDD Ruling Since all AML programs are customized based upon the size and risk of a Mortgage Lender, Broker or Individual Licensee, the application of the “fifth” pillar must be factored into all programs beginning on May, 11, 2018. Therefore all AML programs must be modified …