Developing an anti-money laundering program (AML) can prove challenging for card processing companies. While not an exhaustive list, here are 9 areas that an AML program should be sure to include:
- Firm Policy – A general written AML policy reflecting the fulfillment of the obligations set forth in the AML program.
- AML Compliance Person – Designation of an AML compliance person along with a description of his or her duties.
- Merchant Identification Program – A description of how merchants are identified and how their identities are verified.
- Merchant Due Diligence – A description of the merchant due diligence process (this is in addition to merchant identification procedures).
- Record-Keeping – A description of record-keeping procedures as they relate to merchant identification, merchant due diligence and any other AML program-related records or documents (such as suspicious activity reports).
- Suspicious Activity – A description of merchant activity monitoring and the steps taken when suspicious activity is detected.
- Employee Training – A description of ongoing employee AML training and programs.
- Checking OFAC Listings – An explanation of how all merchant accounts are checked against the specially designated nationals and blocked person list issued by the U.S. Treasury’s Office of Foreign Assets Control (OFAC).
- Audit Process – A description of the independent testing function that will be used to assess AML program compliance.