AML/SAR Policy and ProceduresWe have posted a draft AML/SARs policy to be included in your policies and procedures. It cover the enhanced file review for money-laundering, self-employed businesses and the SAR reporting matrix and procedure. Remember that our procedures already covered reviewing for fraud - this expands that review to cover the new mandate.
Go to Mortgage Manuals Download Site to check your subscription status and download the policy.
We have provided an update to the Quality Control Plan which addresses enhanced guidance for review of deposits and self-employed borrowers in money businesses, and provides the reporting procedures for ALL suspicious activity.
Fraud Red Flags
It is important to note that the mortgage industry already reviews for Fraud Red Flags, and if you are a Mortgage Manuals customer, you have 95% of this in place. This update enhances guidance for reviewing deposit Red Flags (by adding several items to the production quality control checklist). It enhances the review of Self-Employed borrowers for transactions and structures that lend themselves to Money Laundering.
Non-currency businesses were not previously required to report. This policy updates the QC plan by memorializing
- The process for identifying Reportable Events
- The process for reporting SARs
- Using FINCEN Reports in your own reporting
We were developing an AML SAR Reporting Training Program, until we realized that many of our customers already have this in place, either through the Bank AML procedures or through Continuing Education programs. If you require a generic AML Program, please do not hesitate to contact us directly at 202-550-5626.