ICAS Anti-Money Laundry
ICAS requires that all their agents adopt a written AML Compliance Program that is reasonably designed to ensure proper record keeping and reporting of certain transactions, and to prevent your business from being used to launder money.
Your ICAS Compliance Program must include, at a minimum, the following:
A. Adoption of a written AML program with internal policies, procedures and controls for:
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Verifying customer identification
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Filing reports as required by your local regulations
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Creating and retaining records
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Responding to law enforcement requests
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Licensing requirements
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Compliance with local regulatory requirements
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Employee and Compliance Officer training
B. The designation of a Compliance Officer who is responsible for assuring that:
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Policies and procedures are followed
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Procedures are updated as needed
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Training and education are provided
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Reports are filed required by your local regulations
C. An ongoing employee training program that:
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Explains policies and procedures
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Teaches how to identify suspicious activity
D. A Periodic Review of your AML program:
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The review should take place as needed and be as thorough as needed based on the risks specific to your business and the requirements of the local regulations.
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The review must be conducted by the person identified as qualified per the local regulations. If none is specified, the review may be performed by one of your employees, but cannot be performed by your Compliance Officer.
The information contained in this Guide will provide your business with the tools it needs to build an AML Compliance Program that meets the minimum requirements of ICAS.
In order to be fully compliant, your business’s Compliance Program must also meet the local regulatory requirements. your job without taking shortcuts, or putting the safety of yourself or others at risk.
The quality and effectiveness of the program depends on your commitment to it. The only opportunity to verify customer information and identify suspicious activity is at the point of sale. This can only be done with a knowledgeable, well-trained staff.
Your ICAS Compliance Program must include, at a minimum, the following:
First, your business should formally adopt an AML Compliance Program. This Guide can serve as the basis for that program, however, you must check with your local regulations for the specific requirements for adoption of a Compliance Program. form that can be used to certify adoption of such a program.
Second, your business must designate a Compliance Officer. The Compliance Officer may be an employee who has other duties at your business, but it should be someone in a responsible position. The Compliance Officer is responsible for your business’s day-to-day compliance with the AML laws and regulations, and for ensuring the Compliance Program is updated as needed. The Compliance Officer is also responsible for overseeing your business’s ongoing education and training program. When you designate a Compliance Officer, verify that the qualifications of that person meet the local requirements and document it accordingly. You can complete the sample Designation of Compliance Officer form shown and then retain it in your AML compliance files.
Third, your business must adopt policies and procedures for the identification and reporting of Suspicious Activity and High Currency Amount Transaction Reports. You must check with your local regulations for these thresholds and what it considered to be a suspicious transaction as well as the allowable time delays to report such activity. If you’re business plans to impose stricter thresholds than those required by your government, those should be included in your Compliance Program.
Fourth, your business must establish an ongoing employee-training program for all employees who will have any involvement with the activities. The education and training should include instruction on the employees’ responsibilities under the program, as well as the detection of suspicious transactions. One good tool for training is this Guide. All employees should be required
First, your business should formally adopt an AML Compliance Program. This Guide can serve as the basis for that program, however, you must check with your local regulations for the specific requirements for adoption of a Compliance Program. form that can be used to certify adoption of such a program.
Second, your business must designate a Compliance Officer. The Compliance Officer may be an employee who has other duties at your business, but it should be someone in a responsible position. The Compliance Officer is responsible for your business’s day-to-day compliance with the AML laws and regulations, and for ensuring the Compliance Program is updated as needed. The Compliance Officer is also responsible for overseeing your business’s ongoing education and training program. When you designate a Compliance Officer, verify that the qualifications of that person meet the local requirements and document it accordingly. You can complete the sample Designation of Compliance Officer form shown and then retain it in your AML compliance files.
Third, your business must adopt policies and procedures for the identification and reporting of Suspicious Activity and High Currency Amount Transaction Reports. You must check with your local regulations for these thresholds and what it considered to be a suspicious transaction as well as the allowable time delays to report such activity. If you’re business plans to impose stricter thresholds than those required by your government, those should be included in your Compliance Program.
Fourth, your business must establish an ongoing employee-training program for all employees who will have any involvement with the activities. The education and training should include instruction on the employees’ responsibilities under the program, as well as the detection of suspicious transactions. One good tool for training is this Guide. All employees should be required
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