26 Yucca Drive
Staten Island, NY 10312
ph: 718-317-1150
alt: 917-674-8423
dtilzer
The USA PATRIOT Act, Section 352, requires all financial institutions and Money Services Businesses (MSBs) to be in compliance with the four sections of Section 352. MSBs are also required to be registered with FinCEN unless they are agents of a License Holder who is registered, generally money transmitters and the issuers of money orders and traveler’s checks.
A.M.L. Protective Service is a small consulting company that can provide you with what you need to come into or remain in compliance. By offering one-on-one service, we will ensure that you not only come into compliance, but understand what you need to do to remain in compliance. We are also here to speak to your employees or members of your associations at any meeting. We provide presentations on numerous topics, many of which have been given CPE accreditation. Please see our section on some of these topics
If you are a financial institution, a Money Services Business (MSB), you may be required to register with FinCEN. Ask yourself the following questions -
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.
Copyright 2010 AML Protective Services. All rights reserved.
26 Yucca Drive
Staten Island, NY 10312
ph: 718-317-1150
alt: 917-674-8423
dtilzer