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ANTI-MONEY LAUNDERING DEBUTS FOR …

MAGAZINE ARTICLE. March 2012. National Mortgage Professional Magazine ANTI-MONEY LAUNDERING . DEBUTS FOR NONBANKS. JONATHAN FOXX *. A new era in filing requirements is about to begin. For the first time, the Financial Crimes Enforcement Network, known as FinCEN, will require nonbank mortgage lenders and originators to implement an ANTI-MONEY LAUNDERING program ( AML Program ) and file Suspicious Activity Reports ( SARs ) for certain loan FinCEN is establishing this AML program in accordance with the Bank Secrecy Act ( BSA ).2 The guidelines relating to the AML requirement become effective on April 16, 2012, and the AML Program's effective compliance date is August 13, The AML program and SAR filing regulations, which I will refer to as FinCEN's rule, are considered to be the first step in an incremental approach to implementation of regulations for the broad loan or finance company category of financial institutions. 4. The Bank Secrecy Act defines the term "financial institution" to include, in part, a loan or finance company.

© 2012 Lenders Compliance Group, Inc. and © 2012 NMP Media. All Rights Reserved. This article is published in National Mortgage

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