A.M.L. PROTECTIVE SERVICES

If you are a financial institution, a Money Services Business (MSB), you may be required to register with FinCEN.  Ask yourself the following questions -

• Do you issue/sell/redeem money orders, traveler's checks, or stored value instraments, for more than $1000/day/customer?
• Are you an agent of the institution that issues those products?
• Are they registered?
• Do you transmit funds in any amount?
• Do you cash checks for morethan $1000/day/customer?
• Do you exchange currency for more thsn $1000/day/customer?

Your responses to the above questions will determine your registration requirements.  Contact us for more information.

Do you have your compliance manual, your Policies & Procedures, that describes your day-to-day activities and what you and your employees must do to ensure that your company is not being utilized by someone to launder money through you.  Does your manual address all the services that you provide - check cashing, money orders, traveler's checks, funds transmission, etc.?  Does your manual address SAR identification and SAR filings?  Does your manual address the filing of CTRs or other required filings?  These are some of the areas that need to be addressed.  Have any questions?  Contact us for more information.

Who is your compliance officer?  Do you have that person designated so that you and your employees know who the compliance officer is and, most importantly, how to contact that person for help with questions or problems?  What is that person's qualifications to be the compliance officer?  Do you need to hire someone for that position?  Contact us for more information.

Have you and your employees been properly trained for the products and services you provide?  Do they understand the filing requirements and potential consequences of not being in compliance?  Have they been tested to judge their understanding?  Do you have this documented/  When was the last time they were trained and what did the training include?  And, who performed this training?  If you are not sure of what needs to be covered or how often, we can help you.  Contact us for more information. 

When was the last time you had the required independent audit conducted?  Do you know how often it is required?  Simply, it is required periodically and how often is based on your company's RISK level.  The more risk, the more services you offer, and the more destinations involved, the more often you may need this performed.  When the review was conducted, did the reviewer understand your business and address all the relevant areas?  At the conclusion of the review, did you receive the report in a timely manner and did it  identify all products and services you provide?  Were the findings and recommendations discussed with you?  Did you understand the findings and recommendations?  Finally, when the review was conducted, what were the qualifications of the person who performed the audit?  Was he CAMS certified?  At A.M.L. Protective Services we are CAMS certified and here to assist you to come into and remain in compliance, which is what your regulators require.  Contact us for more information.