Policy and Procedures for Suspicious Activity Reporting (SAR) and Anti-Money Laundering (AML) Program

AUM HOME LOAN CORP

Policy and Procedures for Suspicious Activity Reporting (SAR) and Anti-Money Laundering (AML) Program

 

Introduction:

AUM HOME LOAN CORP (“Company”) is committed to complying with the Bank Secrecy Act (BSA) and its implementing regulations issued by the Financial Crimes Enforcement Network (FinCEN). This policy outlines our Suspicious Activity Reporting (SAR) and Anti-Money Laundering (AML) program designed to prevent, detect, and report suspicious activity that may be related to money laundering, terrorist financing, or other illegal activity.

Scope:

This policy applies to all employees, agents, and representatives of the Company involved in mortgage loan origination, servicing, or related activities.

Definitions:

Suspicious Activity: Any activity that deviates from a customer’s expected behavior or is indicative of possible involvement in money laundering, terrorist financing, or other illegal activity.

 

Suspicious Activity Report (SAR): A formal report filed with FinCEN to report identified suspicious activity.

 

Anti-Money Laundering (AML): The set of procedures and policies aimed at preventing criminals from using the financial system to launder money generated from illegal activities.

Program Components:

  1. Customer Identification Program (CIP):
  • We will verify the identity of all customers and beneficial owners of legal entity customers in accordance with FinCEN regulations.
  • We will obtain and document required identification information, such as government-issued photo IDs and legal documents.
  • We will verify the accuracy of information provided through independent sources.
  1. Customer Due Diligence (CDD):
  • We will assess the risk associated with each customer and their transactions based on factors such as source of funds, transaction size and frequency, and geographic location.
  • We will conduct ongoing monitoring of customer activity to identify any suspicious patterns.
  • We will implement enhanced due diligence for high-risk customers.
  1. Currency Transaction Reporting (CTR):
  • We will file CTRs with FinCEN for currency transactions exceeding $10,000.
  • We will maintain records of all currency transactions for at least five years.
  1. Suspicious Activity Detection and Reporting:
  • We will educate all employees on identifying and reporting suspicious activity.
  • We will establish a clear and accessible process for reporting suspicious activity.
  • We will investigate all suspicious activity reports promptly and thoroughly.
  • We will file SARs with FinCEN for any identified suspicious activity.
  1. Recordkeeping:
  • We will maintain accurate records of all CIP, CDD, and SAR activities for at least five years.
  • We will have a system in place to ensure the security and confidentiality of all records.
  1. Internal Controls:
  • We will conduct reviews to ensure the effectiveness of our AML program.
  • We will take corrective action to address any identified deficiencies.
  • We will maintain a compliance management system to track and manage AML risks.
  1. Third-Party Relationships:
  • We will ensure that all third-party vendors we work with comply with applicable AML regulations.
  1. Training and Education:
  • We will provide regular training and education to all employees on AML regulations and compliance procedures.
  • Training will cover topics such as identifying suspicious activity, reporting procedures, and CIP requirements.
  1. Reporting and Disclosure:
  • We will file all required reports with FinCEN.
  • We will maintain accurate records of all AML compliance activities.
  1. Regulatory Updates:
  • We will stay up-to-date on all FinCEN regulations and implement necessary changes to our policies and procedures.

Enforcement and Accountability:

  • We will take disciplinary action against any employee who violates FinCEN regulations or this policy.
  • We will report any identified violations to FinCEN as required.

Communication and Transparency:

  • We will communicate our commitment to AML compliance to all employees and customers.
  • We will provide information about AML regulations and our compliance policies on our website and in other communications.

This policy is intended to be a comprehensive guide to AML compliance for the Company. We will periodically review and update this policy to reflect changes in FinCEN regulations and our business practices.

Contact Information:

For any questions or concerns regarding AML compliance, please contact us