Anti-Money Laundering Policy (AML)

This is a policy guide to comply with Anti-Money Laundering requirements under the Bank Secrecy Act as a mortgage banker. This is a separate policy guide. Once purchased this guide will be customized to your specifications. You will receive an immediate invoice receipt with a download link to a questionnaire with some simple questions to answer and receive your customized guide within 24-48 hours. This is written for independent mortgage bankers but can be customized for depository financial institutions and credit unions. 

Table of Contents

ANTI-MONEY LAUNDERING POLICY

• Purpose
• Scope

CUSTOMER IDENTIFICATION      

• Customer Identification Program (CIP)
• Documenting Customer Identification
• ID Verification Process
• Identity Verification Failure
• Customer Refusal or Inability to Provide Information

AML PROCEDURES         

• OFAC/SDN List Comparison
• Use of Third-Party Tools
• Red Flags
• Subpoenas

AML COMPLIANCE OFFICER

REPORTING

• Suspicious Activity Reporting (SAR)
• Timing
• Confidentiality of SAR Reports
• Information Sharing with Fannie Mae and Freddie Mac
• Information Sharing with Investors

RECORD RETENTION