Lesson Nine – Recap of the Steps
Here’s a quick recap of the steps you need to take if you suspect fraud or money-laundering activities.
Identify one or more red flags that may indicate suspicious or fraudulent activity. Review all file documentation provided and compile the information.
If red flags are present in the loan file, complete the Preliminary Report of Suspicious Activity report or document(s) your company has provided to you, gather all information you have and send the documentation along with the Preliminary Report of Suspicious Activity to your AML Compliance Officer. The AML Compliance Officer will inform you of next steps and any additional information that may be needed.
Do not discuss the information with anyone other than the AML Compliance Officer.
The AML Compliance Officer will not tell you if a SAR is filed, as the filing of SARs is confidential.
The AML Compliance Officer will investigate the information and communicate with the wholesale lender involved with the transaction. The AML Compliance Officer also may request additional information from you, and will communicate next steps with you and advise you on how to proceed with communication. It is important to follow the AML Compliance Officer’s instructions and NOT discuss the information with anyone unless instructed by the AML Compliace Officer to do so.
This course has covered a lot. The goal was to provide you with an understanding of the requirements of the BSA and the elements of an effective AML Policy. Remember, if you see something suspicious, speak up. It’s the right thing to do.