• Adopted formal AML policies and procedures for Bank Secrecy Act/Anti-Money Laundering Compliance, including the Bank Secrecy
Act/Anti-Money Laundering Compliance Program?
• Completed and signed a “Company Resolution” confirming adoption of formal policies and procedures for Bank Secrecy Act/Anti-Money Laundering Compliance?
• Designated a Company Compliance Officer?
• Required that the Compliance Officer review the necessary laws and AML Compliance regulations?
• Started an Anti-Money Laundering employee training program?
• Provided to all new and existing employees and management personnel a copy of an “Employee Guide to Anti-Money Laundering Laws and Regulations”?
• Made arrangements for proper storage and filing of all documents pertaining to the Bank Secrecy Act/Anti-Money Laundering Compliance program for a period of five years?
• Developed a Daily Procedure Checklist?
• Had an Annual Independent Review of your AML Program?
• Registered as a (MSB) Money Service Business with FinCen?
• Obtained a Check Casher’s Permit from the State of California?
• Incorporated Policies, Procedures and Internal Controls to assure compliance with the BSA?
If you cannot answer “YES” to all of these questions, your business could be at risk under the laws of the USA PATRIOT ACT!