FinCEN Requires an Annual Independent Review of the Program

We hear it all the time. "Why do we need an Anti-Money Laundering (AML) program? We don't handle cash transactions."  Or, "The Bank Secrecy Act (BSA) doesn't apply to us. We're not a bank." But the AML program is designed to ferret out money laundering activities of all kinds, and any positive finding using mortgage industry's Red Flag reviews represents a potential Suspicious Activity Report (SAR) requirement.

State Regulators Enforce BSA/AML Rules

Mortgage firms commonly receive regulatory citation for failing to have, implement or review AML/BSA programs. We provide the plans, but failing to implement or review the plan can be just as bad as not having one. 

Third-Party Reviews

Our plans provide a self-audit function, but if your firm cannot document independence, the state regulator may require a 3rd-party review. States which require a third party review regardless of independence include:

• New York
• Oregon
• Washington
• North Carolina

Our 24 Hour AML-BSA Annual Audit Service

Our advanced automation allows us to compile, review and issue a complete annual audit report in a very short period of time - 24 hours guaranteed, from when you submit all required information. In addition, if you are missing information in your plan, haven't taken AML training, or need remediation, we can help with all of those things. 

Sample AML Audit Report

Upon Completion of the order, you will receive a link to access the questionnaire which commences the audit. If you are using a non-mortgagemanuals.com BSA/AML plan, please add-on for policy review service.

A note on 3rd party plans: Over the past 5 years we have reviewed over 200 various 3rd party plans. It takes us a long time to conduct this review, and 92% of plans are deficient. Only a portion of the AML audit deals with the BSA/AML plan, but if you have a poor plan, it is also likely that you aren't in compliance either.