Step 2: Customer Due Diligence (CDD) & KYC
Do you have a written Customer Identification Program (CIP)?
Do you verify the identity of every customer using reliable documents or methods?
Do you perform risk-based due diligence to understand the nature of customer relationships?
Step 3: Monitoring & Reporting
Do you have a process to monitor transactions for suspicious activity?
Do you file Suspicious Activity Reports (SARs) with FinCEN when required?
Do you file Currency Transaction Reports (CTRs) for cash transactions over $10,000?
Step 4: Formal AML Program
Do you have a formal, written AML compliance program approved by management?
Have you designated a qualified AML Compliance Officer?
Do you provide ongoing AML training for all appropriate personnel?
Do you conduct independent testing or audits of your AML program?
