“When our bank asked us to put an AML Compliance plan in place and recommended Knaus & Associates, we were apprehensive about the process. Working with Gary has been a pleasure. He not only provided an excellent program and review, but has educated us on how to properly implement our program. And, he is always available to answer our questions. We highly recommend his firm.”
Sam Rafida
European Jewelry & Repair, Inc.
The Four Pillars of an Anti-Money Laundering Program
To achieve compliance, you must have the following:
- A written compliance plan that includes a risk assessment and the identification of processes and procedures to prevent money laundering by your customers and suppliers.
- Designation of a Compliance Officer who oversees the program. Responsibilities include program monitoring, implementation, training and an ongoing assessment of risks. The Compliance Officer must be an employee of your firm and is typically the owner, a senior manager or the individual in charge of your firm’s finances.
- Employees must be trained at least once a year on the AML processes and regulations germane to your business. New hires, including outside consults involved in purchasing and selling, are required to be trained within 15 days of hire. Each individual receiving training must sign a statement acknowledging their understanding of AML regulations.
- A periodic independent test (review) of your AML program. Larger firms and those at higher risk should have the review performed annually.
Anti-Money Laundering Compliance Programs
Knaus & Associates creates AML Compliance Programs that meet federal requirements. As required by law, each program is customized to the types of products you buy and sell, the specific risks you are exposed to in transactions, and the identification of processes and procedures that greatly reduce those risks. The written training materials and self-exam are designed to focus on risks and transactions distinct to your business. Employee signature pages are also provided as well as sample reporting forms, OFAC information and a copy of the regulations themselves.
Your Customized AML Compliance Program will include the following components:
- Overview
- Table of Contents
- Written Compliance Program
- Designation of Compliance Officer
- Written Training Materials with Examination and Answer Key
- Employee/Consultant Signature Forms
- Samples of Forms 8300, 1099-B and SARs as well as OFAC information
- Copies of Federal Regulations Pertinent to Dealers in Precious Metals and Precious Stones
Ready to Find Out More?
For a free confidential assessment to determine if your firm needs an AML Compliance program or your existing program meets minimal requirements, please call (630) 963-6350 or use the "Contact Us" button to access our contact form.
Periodic Independent AML Program Reviews
If your business meets the minimum requirements for having an AML Compliance Program in place, then you must also have a periodic independent review of the program. The review is the fourth pillar of AML Compliance. This review (sometimes termed a test) assesses:
- Financial sales and purchase records to determine if forms 8300 and 1099-B were required and if so if they were filed in a timely manner
- Purchase and sales recordkeeping and adequateness of information collected from customers and suppliers
- Identification of potentially structured or related transactions.
- Areas of weakness in the above along with specific recommendations for addressing shortcomings
The Compliance review is NOT a financial review or audit of your business as typically provided by accountants – this review is focused for AML compliance.
Furthermore, the review MUST be performed by an independent third party.
Let's Talk
For a confidential discussion of your Annual Review needs, please call (630) 963-6350 or use the "Contact Us" button to access our contact form.
Anti-Money Laundering Compliance Training
Clients who have existing Compliance Programs sometimes request that we create training materials and examinations with case studies that focus on issues highly specific to their business. Issues covered may include areas of identified shortcomings, the types of customers they serve and the material they sell. Through examples the case studies and training documents breathe life into and clarify how to handle specific situations that arise in day-to-day operations.
In addition to providing written materials, Knaus & Associates can conduct on-site training. Alternatively, we offer more convenient and much less expensive training via Skype.
Get in Touch
If you'd like to discuss having Knaus & Associates prepare a customized training program, please call (630) 963-6350 or use the "Contact Us" button to access our contact form.
Preparing for an IRS Title 31 (AML) Audit
During a routine audit of your business by the IRS, if deficiencies are identified with your Anti-Money Laundering Compliance Program you may be fined and/or given a period of time to become fully compliant. If AML deficiencies are found, the IRS will return to perform a Title 31 Audit. During this audit the IRS comprehensively reviews your AML program and Independent review. They will assess the processes and procedures you have in place, your recordkeeping, risks unique to your business, employee training and training records. Your will have your bank records and your sales and purchases receipts audited to make sure they match. And, they will seek to identify violations and possible structured transactions.
Because the risk of adverse findings during this audit can lead to substantial penalties and fines, credit issues with your financial institution plus a potentially adverse impact on your firm’s reputation, it is highly advised to seek help prior to this audit. Knaus & Associates can help. Please call for a confidential consultation.
Questions? Contact Us for a
Confidential Consultation.