Compliance with Anti-Money Laundering Regulations

Reporting Requirements for Currency Transactions Involving Government Officials

Financial institutions must comply with strict regulations when dealing with currency transactions exceeding $10,000 involving government officials. Here are the key points to note:

Reporting Large Currency Transactions

• Financial institutions must file a Currency Transaction Report (CTR) for transactions involving currency exceeding $10,000.
• When dealing with government officials, financial institutions only need to obtain identifying information related to the agency involved, not the individual official.

Conducting Independent Reviews of Anti-Money Laundering Programs

Money services businesses are required to have anti-money laundering programs that include an independent audit function to test their programs. Here’s what you need to know:

Review Process

• The review can be conducted by an officer or employee of the money services business, as long as the reviewer is not the designated compliance officer and does not report directly to them.
• The scope and frequency of the review should be commensurate with the risk faced by the financial services provided by the money services business.

Documenting Review Findings

After conducting a review, the reviewer or the designated compliance officer must document:

• The scope of the review
• Procedures performed
• Transaction testing completed (if any)
• Findings of the review
• Recommendations to management for corrective actions (if any)

Accessibility of Documents

All documentation related to AML reviews should be made accessible to government examiners and law enforcement personnel who have authority to examine such documents.

By following these guidelines, financial institutions can ensure compliance with anti-money laundering regulations and maintain a secure and transparent financial system.