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 for additional risk-based procedures (CDD Rule). “For FinCEN, the key elements of CDD include: (i) Identifying and verifying the identity of customers; (ii) identifying and verifying the identity of beneficial owners of legal entity customers (i.e., the natural persons who own or control legal entities); (iii) understanding the nature and purpose of customer relationships; and (iv) conducting ongoing monitoring. Collectively, these elements comprise the minimum standard of CDD, which FinCEN believes is fundamental to an effective AML program”
FINRA has created a template from which we have made adjustments to apply the template to a small organization based upon what would be reasonable procedures for them.
In a recent case FinCEN assessed 14.5 Million Penalty against UBS for AML failures https://www.fincen.gov/news/news-releases/fincen-assesses-145-million-penalty-against-ubs-financial-services-anti-money
Federal Agencies also recently issued a joint statement encouraging innovative industry approaches to AML Compliance.
CLOES.online offers the first low-cost AML Compliance Training Program with verifiable annual certification by companies and regulators.
What this means is that every company now will have access to the latest AML programs and procedures training and certification by financial experts.
Our 2019 AML Program is a complete learning management system covering all aspects of AML programs and training including:
- Identification and Validation of Photo ID
- Updated NMLS Approved BSA/AML Video Training 50 Minutes
- Annual Review Training and Knowledge Assessment
- Independently Verified Certificate of Compliance
CLOES.online AML Program provides a standard AML program that is customized for a Small Firm and or Individuals wanting to be sure they are covered even though the company they work for has no clue about AML.
At CLOES.online we believe every licensed mortgage originator has his own personal obligations to comply with the law.
AML Course also includes an active BLOG on the latest information for AML compliance individuals and licensees. We apply the information only to mortgage loan originators.
The AML program can also be customized and expanded for larger companies with more extensive requirements.
All AML courses include automatic reminders and triggers to alert users to past and coming deadlines.
Lenders can bulk purchase for employees at discounted rates.
CLOES.online specializes exclusively in mortgage loan originator training.
Contact Deb Killian at firstname.lastname@example.org