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Anti-Money
Laundering Examination Questionnaire
Full Name of Person Completing Questionnaire:
*
First Name
MI
Last Name
Phone Number:
*
-
Area Code
Phone Number
E-mail Address:
*
Company Name:
*
Please complete the number of staff by position
:
Owners:
Loan Officers:
Processors:
Operations:
Other:
1) Has your AML Compliance Program been approved by the company Board of Directors and Senior Manager?
*
Please Select
YES
NO
2) Does your company have a designated Compliance Officer that is responsible for legal & regulatory compliance?
*
Please Select
YES
NO
2b) If yes to Q2 please give Compliance Officers name:
3) Does your company have written Anti-Money Laundering Policies & Procedures in place?
*
Please Select
YES
NO
4) Aside from government regulators, does your company have an internal AML exam function or a third party that assesses your AML programs?
*
Please Select
YES
NO
5) Does the company have record retention procedures that comply with AML required law?
*
Please Select
YES
NO
6) Are the company's AML policies & procedures being applied to all branches and subsidiaries?
*
Please Select
YES
NO
7) Does the company have a risk based assessment of its customer bases & transactions?
*
Please Select
YES
NO
8) Does the company determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the company has reason to believe pose a heightened risk of illicit activities at or through the company?
*
Please Select
YES
NO
9) Does the company have procedures to establish a record for each new customer noting their respective identification documents and ‘Know Your Customer’ information?
*
Please Select
YES
NO
10) Does the company have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?
*
Please Select
YES
NO
11) Where cash transaction reporting is mandatory, does the company have procedures to identify transactions structured to avoid such obligations?
*
Please Select
YES
NO
12) Does the company screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities?
*
Please Select
YES
NO
13) Does the company have a monitoring program for unusual and potentially suspicious activity that covers funds transfers, etc?
*
Please Select
YES
NO
14) Does the company provide annual AML training to relevant employees that includes: A) Identification and reporting of transactions that must be reported to government authorities. B) Examples of different forms of money laundering involving the company's products and services. C) Internal policies to prevent money laundering.
*
Please Select
YES
NO
15) Does the company retain records of its training sessions including attendance records and relevant training materials used?
*
Please Select
YES
NO
16) Does the company communicate new AML related laws or changes to existing AML related policies or practices to relevant employees?
*
Please Select
YES
NO
17) Does the company have a written "Red Flags" policy that is kept current?
*
Please Select
YES
NO
18) Does the company employ third parties to carry out some of the functions on behalf of the company?
*
Please Select
YES
NO
19) What systems and procedures are used to detect and report suspicious activity during the mortgage application process?
*
EXAMPLE: The company utilizes its AML policies & procedures and reviews each loan application throughout the processing of the loan.
20) What type of transactions will require the company to file an SAR?
*
EXAMPLE: Any suspicious or criminal activities detected from the loan applicant.
21) What kind of investigation does the company conduct when a red flag occurs? Who does it?
*
EXAMPLE: Whenever a red flag occurs the employee(s) notifies the Compliance Officer who makes determination as to the required investigation.
22) How promptly must employees report potential suspicious activity; to whom do they report it?
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EXAMPLE: Employees must report any criminal or suspicious activity immediately upon detection to the company compliance officer.
23) Which supervisory personnel evaluate the activity and determine whether the firm is required to file a Suspicious Activity Report with FinCEN?
*
EXAMPLE: When activity is detected the company compliance officer evaluates documentation & employee(s) statements to determine if a SAR is to be filed.
24) Are Loan Officers screening applicants and dropping them avoiding a SAR being generated before credit is pulled?
*
Please Select
YES
NO
24b) If answered Yes, please give detailed explanation why this is happening:
25) Are there adequate explanations for denied loans not to have SARs being issued?
*
EXAMPLE: Yes. All loans applications must have written reasons for cancellation or decline in the loan file records.
26) Do all credit bureau pulls have corresponding loan applications?
*
Please Select
YES
NO
26A) If answered NO to question 26 please state the reason(s):
27) Does total of credit bureau pulls equal the total of closed, canceled and denied applications?
*
Please Select
YES
NO
27A) If answered NO to question 27 please state the reason(s):
28) Have you filed any SAR's (Suspicious Activity Reports) with FinCEN?
*
Please Select
YES
NO
28A) If YES to question 28 give the total numbers of SAR's filed, the time period and list each report by CIP (Loan Number & Borrower Name):
29) What are the consequences if an employee does not follow the company's AML policy?
*
EXAMPLE: The employee is subject to written corrective action or termination if unable to correct.
30) Who in senior management is responsible for written approval of the company's AML program?
*
ANSWER NOTE: Insert name of Senior Manager who signed the companys AML policy.
31) Has the company designated one or more individuals to be responsible for overseeing the day-to-day operations of the firm’s AML compliance program? Names of those whom the firm designated?
*
EXAMPLE: The company Compliance Officer is fully responsible for the company's AML program.
32) Does the AML Compliance officer/department report to senior management? If so, to whom?
*
ANSWER NOTE: Usually the senior manager and compliance officer are the same person. If so, simply state so. If not, give both names & titles.
33) What are the AML Compliance Officers duties and responsibilities?
*
EXAMPLE: The Compliance Officers duties are to oversee the company AML program, assure AML training education and to file SAR reports and/or notify law enforcement when required.
34) Who in senior management or the audit committee receives the results of the independent audit?
*
ANSWER NOTE: Usually the senior manager and compliance officer are the same person. If so, simply state so. If not, give both names & titles.
35) How will the firm address deficiencies noted in the annual AML audit report?
*
EXAMPLE: If the report contains deficiencies the company will make corrections to its AML policies & procedures and conduct additional employee training.
36) When are new employees trained on the company's AML Program?
*
EXAMPLE: All new employees receive training on AML and other company policies before any work (customer contact) is permitted.
37) What is the name of Company that conducts your annual AML training for all employees?
*
Please Select
GMLA/OnlineEd
Walsh Agency
Self-In House
Other
37a) If Self/In House or Other outside (not listed) AML annual training, please give name of trainer or training company and their contact information:
*
Submit
Should be Empty: