Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor
Published by Civic Research Institute
Anti-Money Laundering Program Flowchart

This step-by-step "Compliance Flow Chart" details every key relationship and requirement financial institutions must manage to ensure compliance with Federal anti- money laundering regulations... 

The Compliance Flow Chart summarizes a financial institution's essential responsibilities in operational sequence, much like a corporate organizational chart.

On the left are customers, individuals and entities that, intentionally or innocently, may become involved in money laundering activities or may be suspected of supporting the activities of criminals or terrorists.  The first line of the institution's defense will involve those units deemed points of entry or points of exit, including tellers, trust, loan, and international departments, specialized units such as private banks and correspondent banking areas, foreign exchange and foreign branch offices, credit card operations, and online activities. Some institutions, such as mutual and hedge funds, may transfer certain responsibilities to other institutions, resulting in responsibilities being spread across several institutions. These points of entry have become a principal focus of regulation through implementation of customer identification programs.  Each institution must become familiar with the identification responsibilities that apply to its operations.            

The flowchart also identifies the responsibilities that management information systems have for capturing and processing data identified by regulators.

Administrative and internal audit functions, as well as training units, must oversee and review implementation of anti-money laundering responsibilities throughout the institution. An institution may also be advised to obtain an external audit, and can expect to have various contacts with outside agencies, including federal and state agencies, and self-regulatory organizations, as listed on the right panel of the flowchart. Cooperation and support in the war on terrorism does not stop at the U.S. border, however, and many international agencies, including the United Nations and the Organization of Economic Cooperation and Development, have considerable influence on the pronouncements of domestic agencies such as the Financial Crimes Enforcement Network and the Office of Foreign Assets Control.

To order copies of this 24" x 36" color poster for your institution, click here.



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[Federal Register: 2004-2003 2002 2001 2000-1996]
[Money Laundering, Terrorism & Financial Institutions Online]
[Legislative Materials] [Agency Reports: GAO Treasury]