Mortgage Companies are required to have an audit of their AML program. Failure to do so can result in criminal proceedings, large fines and loss of license for the company.
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As part of the BSA Act from FinCEN an independent audit of your AML program must be conducted no less than every 18 months. These audits are structured to help you pass the requirements established form your State auditors.
As part of the BSA Act from FinCEN an independent audit of your AML program must be conducted no less than every 18 months. These audits are structured to help you pass the requirements established form your State auditors.
An audit consists of these procedures
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Objective and scope of an AML audit consists of:
The audit is conducted pursuant to the Financial Crimes Enforcement Network’s (FinCEN) and the Internal Revenue Service’s (IRS) rules and regulations. The objectives of the audit are to determine if the RMLO being audited has, and is adhering to the government’s anti-money laundering regulations as covered in the AML programs of said RMLO. The audit includes: a review of the current requirements under the AML program of the RMLO, a review with the principals and employees of the RMLO to ensure they know what is required of them under the Anti-Money Laundering Program (AMLP), and SAR ‘red flags’ and the consequences of not complying with AML rules and regulations. |