Homepage / Fill in a Valid Aml Program Template
Jump Links

The Anti-Money Laundering (AML) Program form outlines crucial policies and procedures designed to ensure compliance with federal anti-money laundering laws. Established by the George Washington University in October 2005 and last amended in June 2014, it reflects a proactive approach to safeguarding university resources against illegal activities. The responsibility for overseeing this program lies with the Senior Associate Vice President for Finance and the Treasury Management Office. The form includes a detailed policy statement emphasizing adherence to various federal regulations, including the Money Laundering Control Act and the Bank Secrecy Act, aimed at preventing illicit transactions. Its primary purpose is to not only fortify compliance but also to aid law enforcement in fighting money laundering activities. Additionally, it identifies key stakeholders—faculty, staff, and students—who must be informed of these policies. The program stipulates specific procedures for customer identification, includes training for university personnel, and establishes reporting guidelines for suspicious activities. Overall, this AML Program form serves as an essential framework to minimize the risk of the university inadvertently enabling financial crimes and to protect the integrity of its operations.

Aml Program Example

Responsible University Official:

Senior Associate Vice President for

Finance

Responsible Office: Treasury

Management

Origination Date: October 2005

Last Amended Date: June 26, 2014

ANTI-MONEY LAUNDERING POLICY

Policy Statement

It is the policy of the George Washington University to comply with anti-money laundering obligations imposed by the federal government, including applicable provisions of the Money Laundering Control Act of 1986, the Bank Secrecy Act, the USA PATRIOT Act of 2001, the rules and regulations overseen by the United States Treasury Department’s Office of Foreign Assets Control and Financial Crimes Enforcement Network, and other legal requirements.

Reason for Policy/Purpose

The purpose of this policy is to enhance the university’s compliance with anti-money laundering laws and regulations, to assist law enforcement in combating illegal money laundering, and to minimize the risk of university resources being used for improper purposes. Failure to comply with anti-money laundering regulations could result in civil and criminal penalties to the university and/or individual faculty, staff and students.

Who Needs to Know This Policy

 

Faculty, staff, and students

 

Table of Contents

Page #

Policy Statement

1

Reason for Policy/Purpose

1

Who Needs to Know This Policy

1

Table of Contents

1

Policy/Procedures

2

Website Address for This Policy

2

Contacts

2

Related Information

3

Who Approved This Policy

3

History/Revision Dates

3

ANTI-MONEY LAUNDERING POLICY

Policy/Procedures

Money laundering is conducting or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activity. To assist the federal government in detecting, preventing, and eradicating criminal and terrorist financing and activity, the university will take all necessary steps to comply with applicable anti-money laundering laws and regulations.

The university will maintain an anti-money laundering program in accordance with the Bank Secrecy Act, as amended by the USA PATRIOT Act, and other applicable federal laws and regulations. The program is reasonably designed to prevent university services from being used to facilitate money laundering and the financing of terrorist activities. The program includes the following:

Procedures to verify customer identification and retain necessary identifying and transactional information;

A designated compliance officer to coordinate compliance with the program;

Suspicious activity reporting procedures and document retention guidelines for any suspicious activity reports and supporting documentation;

Training and education of appropriate university personnel concerning their responsibilities under the program, including suspicious activity reporting; and

Independent review to monitor and maintain an adequate program.

Concerns regarding transactions that are unusually large or that appear suspicious and questions regarding money laundering in general should be directed to the university’s Treasury Management Office at 202-994-0985.

Website Address for This Policy

GW University Policies

Contacts

Subject

Contact

Phone

Money

Treasury Management

703-726-4216

Laundering

 

 

2

ANTI-MONEY LAUNDERING POLICY

Related Information

Bank Secrecy Act, 12 U.S.C. §1951, et seq.

31 U.S.C. § 5311, et seq.

31 C.F.R. Part 1010, 1022

Money Laundering Control Act of 1986, Public Law 99-570 USA PATRIOT Act of 2001, Public Law 107-5

A Brief Primer on Doing Business Abroad: U.S. Laws that Affect GW’s International Activities

Compliance with Law when Conducting University Activities Overseas

Who Approved This Policy

Louis H. Katz, Executive Vice President and Treasurer

Beth Nolan, Senior Vice President and General Counsel

History/Revision Dates

Origination Date:

October 2005

Last Amended Date:

June 26, 2014

Next Review Date:

June 30, 2015

3

File Breakdown

Fact Name Details
Responsible University Official Senior Associate Vice President for Finance
Responsible Office Treasury Management
Origination Date October 2005
Last Amended Date June 26, 2014
Governing Laws Money Laundering Control Act of 1986, Bank Secrecy Act, USA PATRIOT Act of 2001
Policy Purpose To enhance compliance with anti-money laundering laws and protect university resources.
Who Needs to Know Faculty, staff, and students
Procedures Included Customer identification, suspicious activity reporting, and employee training.
Concerns and Questions Call the Treasury Management Office at 202-994-0985.
Policy Approval Approved by Louis H. Katz and Beth Nolan

Guide to Using Aml Program

Completing the AML Program form is essential for ensuring the university meets its legal obligations. Having the correct information available will streamline the submission process, ensuring compliance with anti-money laundering laws. Follow these steps to fill out the form thoroughly and accurately.

  1. Gather your personal and relevant information including your name, title, and department.
  2. Identify and enter the name of the responsible university official, which is the Senior Associate Vice President for Finance.
  3. Include the office responsible for oversight, which is the Treasury Management Office.
  4. Note the origination date of the policy as October 2005 and the last amended date as June 26, 2014.
  5. Read through the policy statement and summarize key points that relate to compliance with anti-money laundering laws.
  6. Review the procedures section and outline the components of the anti-money laundering program required by the university.
  7. Provide details about training and education initiatives for university personnel as per the requirements outlined.
  8. Make sure to add contact details for the Treasury Management Office, including the phone number 202-994-0985.
  9. Check for any additional supporting documentation that may be required to accompany the form.
  10. Review the completed form for accuracy and completeness before submitting it to the appropriate office.

Get Answers on Aml Program

What is the purpose of the Anti-Money Laundering (AML) Program?

The AML Program aims to ensure compliance with various federal anti-money laundering laws and regulations. These include the Money Laundering Control Act of 1986, the Bank Secrecy Act, and the USA PATRIOT Act of 2001. By establishing this program, the university seeks to help law enforcement combat money laundering and minimize risks associated with improper use of university resources. Ultimately, adherence to these regulations protects both the university and its community members from potential civil and criminal penalties.

Who is responsible for overseeing the AML Program?

The Senior Associate Vice President for Finance serves as the Responsible University Official for the AML Program. They oversee the implementation of the policy, ensuring that all university activities comply with the relevant laws. Additionally, the Treasury Management Office plays a key role in coordinating compliance and addressing any concerns related to suspicious transactions.

What procedures are included in the AML Program?

The AML Program encompasses several important procedures designed to prevent money laundering activities:

  • Verification of customer identification and retention of necessary data.
  • Appointment of a designated compliance officer to manage program adherence.
  • Implementation of suspicious activity reporting procedures.
  • Training for university personnel regarding their responsibilities and identification of suspicious activities.
  • Conducting independent reviews to maintain an effective program.

What should I do if I suspect suspicious activity?

If you encounter what seems to be suspicious activity or transactions that are unusually large, it is crucial to report these concerns immediately. You should contact the university’s Treasury Management Office at 202-994-0985 for guidance. Prompt reporting can help prevent potential money laundering and related criminal activities.

Who should be familiar with the AML Policy?

It is essential for faculty, staff, and students to be aware of the AML Policy. Understanding this policy allows all members of the university community to recognize their roles in promoting compliance with anti-money laundering laws. Awareness and adherence to the policy protect not just individual members but also the integrity of the university as a whole.

Common mistakes

Filling out the AML Program form requires careful attention to detail. One common mistake is failing to provide accurate contact information for the responsible university official. Individuals often overlook this part, which can delay communication and compliance efforts. It is essential to ensure that all contact details are current and correctly formatted to facilitate proper identification.

Another frequent error is underestimating the importance of the policy statement. Some people may skim through or misinterpret this section, which outlines the university's commitment to complying with federal anti-money laundering obligations. Neglecting this can lead to a misunderstanding of the policy's scope and related responsibilities.

Inconsistent or incomplete entries regarding the origination and amendment dates are also problematic. Participants sometimes forget to update this information after making changes. Keeping this data precise ensures clarity about the policy's history and helps track revisions accurately.

Misinterpreting the audience who needs to know the policy can result in insufficient dissemination. Not including all faculty, staff, and students who might be affected by the policy can prevent proper awareness and training. It is critical to distribute the information widely to those who need to implement the AML program effectively.

Failing to document suspicious activity and retention procedures is another common oversight. This section is crucial for compliance with regulations. Incomplete guidelines can lead to noncompliance issues, which may expose the university to penalties.

People may overlook the designation of a compliance officer. Without someone responsible for coordinating the program, the institution may struggle to implement the necessary procedures and education outlined in the program. Appointing a compliance officer is essential for ongoing monitoring and proper implementation.

Some individuals forget to include training and education measures for personnel. This part is vital for ensuring staff are informed about their responsibilities regarding suspicious activity reporting. Education plays a key role in a successful AML program and contributes to creating a culture of compliance.

Finally, neglecting to plan for an independent review can hinder the effectiveness of the program. Conducting these reviews helps maintain the program’s integrity and relevance. Ensuring this process is included in the form demonstrates a commitment to compliance and continuous improvement.

Documents used along the form

The Anti-Money Laundering (AML) Program form is crucial in ensuring compliance with various regulations. Alongside this form, several other documents and forms play significant roles in promoting transparency and preventing illicit financial activities. Understanding these documents is essential for anyone involved in maintaining compliance within organizations, especially universities.

  • Customer Identification Program (CIP): This document outlines the procedures for verifying the identity of customers before conducting transactions. It ensures that organizations know who they are dealing with, which is critical to preventing money laundering.
  • Suspicious Activity Report (SAR): A SAR must be filed when financial institutions detect unusual or suspicious activities that may indicate money laundering or fraud. This form helps in reporting potentially criminal behaviors to the relevant authorities.
  • Employee Training Manual: This manual provides guidance and training for staff regarding their roles in AML compliance. It includes protocols for identifying suspicious activities and understanding legal requirements.
  • Compliance Officer Job Description: This document defines the responsibilities and qualifications required for the designated compliance officer. This person will oversee the AML program and ensure adherence to all policies and procedures.
  • Transaction Monitoring Procedures: These procedures detail how an organization will monitor transactions for suspicious activities. Regular monitoring is essential for early identification and prevention of money laundering.
  • Record Keeping Policy: This policy outlines the requirements for maintaining records related to customer transactions, identification processes, and suspicious activities. Proper documentation supports compliance efforts and aids in audits or investigations.

By utilizing these documents in conjunction with the AML Program form, organizations can build a robust compliance framework. A solid AML approach not only meets legal requirements but also fosters integrity and trust within the institution and the larger community.

Similar forms

  • Compliance Manual: Similar to the Aml Program form, a compliance manual outlines all policies and procedures necessary for an organization to adhere to legal obligations. It delineates the roles of designated personnel and the steps for reporting non-compliance.

  • Internal Audit Report: An internal audit report assesses adherence to organizational policies, including anti-money laundering procedures. Like the Aml Program form, it documents findings related to compliance and suggests improvements to maintain regulatory standards.

  • Risk Assessment Document: A risk assessment identifies potential vulnerabilities related to money laundering and other financial crimes. The process is akin to what is detailed in the Aml Program form, emphasizing the importance of risk mitigation strategies.

  • Training Program Materials: These materials are designed to educate employees about compliance responsibilities similar to the training outlined in the Aml Program form. They help ensure all relevant personnel are aware of their roles and the significance of anti-money laundering protocols.

  • Suspicious Activity Report (SAR): A SAR is filed when there is a suspicion of money laundering or fraud, capturing the essence of monitoring transactions. This aligns with the objectives of the Aml Program form to document and report suspicious activities effectively.

  • Policy Statement Document: Like the Aml Program form, a policy statement outlines an organization's commitment to specific legal or regulatory requirements. It provides a clear framework about the institution's stance on compliance, reinforcing a culture of adherence to laws.

Dos and Don'ts

When filling out the AML Program form, it’s important to follow certain guidelines to ensure clarity and compliance. Here are five things you should do and should not do:

  • Do: Read the form carefully before starting.
  • Do: Provide accurate information about your responsibilities.
  • Do: Double-check for any required signatures before submission.
  • Do: Keep a copy of the completed form for your records.
  • Do: Contact the Treasury Management Office with any questions.
  • Don’t: Rush through the form; take your time.
  • Don’t: Leave any fields blank unless instructed.
  • Don’t: Submit the form without required documentation.
  • Don’t: Ignore deadlines; make sure to submit on time.
  • Don’t: Hesitate to ask for help if you're unsure.

Misconceptions

  • Misconception 1: The AML Program form is only for financial professionals.
  • Many believe the form is relevant only to those in finance. In fact, it applies to all faculty, staff, and students at the university.

  • Misconception 2: The AML Program is optional.
  • Some think that participation in the program is voluntary. However, it is necessary to comply with federal laws, and failure to do so can lead to serious penalties.

  • Misconception 3: Only large transactions require scrutiny.
  • It's a common myth that only significant transactions are monitored. In reality, any transaction that appears suspicious, regardless of size, can be subject to review.

  • Misconception 4: The AML Program is outdated.
  • While the form was last amended in 2014, the compliance practices evolve. The program remains relevant and necessary for ongoing protection against money laundering.

  • Misconception 5: Reporting suspicious activity is not important.
  • Some may think reporting is optional, but it is crucial. Timely reporting assists in the fight against illegal activities and is a requirement under the AML Program.

  • Misconception 6: Compliance training is a one-time event.
  • Many assume training happens just once. However, ongoing education is essential for staying current on responsibilities under the AML Program.

  • Misconception 7: The compliance officer only reviews financial records.
  • It's incorrect to think the compliance officer's role is limited. This officer coordinates all aspects of compliance, including training and suspicious activity reporting.

  • Misconception 8: Questions about money laundering should be handled alone.
  • Lastly, individuals often believe they should resolve concerns on their own. Instead, inquiries should be directed to the Treasury Management Office for proper guidance.

Key takeaways

Understanding the Anti-Money Laundering (AML) Program form is essential for compliance and accountability. Here are key takeaways to keep in mind:

  • Know Who Oversees It: The Senior Associate Vice President for Finance is the responsible official for the AML Policy.
  • Policy Compliance: The university must adhere to federal anti-money laundering obligations, including several important laws such as the Bank Secrecy Act.
  • Purpose of the Policy: This policy aims to enhance the university’s compliance and support law enforcement in combating illegal money laundering.
  • Who Needs to Be Informed: Faculty, staff, and students are all required to be familiar with this policy.
  • Verification Procedures: The program mandates procedures for verifying customer identities and maintaining necessary information.
  • Compliance Officer Role: A designated compliance officer will oversee adherence to the AML program.
  • Report Suspicious Activity: There are established procedures for reporting suspicious activities to maintain transparency and accountability.
  • Training Opportunities: Training will be provided to relevant university personnel to understand their responsibilities under the AML program.
  • Independent Reviews: The program will undergo independent assessments to ensure its effectiveness in reducing risks associated with money laundering.

Staying informed and engaged with these key aspects of the AML Program will help protect the university and its community from potential financial crimes.