A customer changes the the place of payment in a letter of credit to an account in a country other than the beneficiary’s stated location

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

Each major subject covered by the Bank Secrecy and PATRIOT Acts contains highly detailed questions patterned after those in the regulatory agencies' auditor manuals. C3 allows you to review each item, track its status as you address any related concerns, and assign accountable parties for specific compliance issues. The reporting capabilities of C3 will significantly simplify your task (as either an auditor or compliance manager) of reporting the completeness of your AML program and remediating any shortcomings.

The C3 Audit Checklist is the single most efficient tool available to conduct the required annual independent audit of your program.

KEY FEATURES & BENEFITS

C3 Audit Control Checklist contains every item covered by the BSA and PATRIOT Act that may potentially be examined by a regulator

C3 Audit Control Checklist identifies all items from your AML compliance program that need ongoing work prior to standing for an actual audit

C3 Audit Control Checklist ensures that you have not overlooked a potential subject that may be covered by an auditor

If you are an internal auditor without specific AML experience, C3 will ensure that your audit of your firm's AML compliance program is sufficiently thorough

C3 Audit Control Checklist allows you to tag audit items with a responsible person so that you can track that person's performance for fulfilling an audit item

The success of a firm's AML program rests on the ability of the Compliance officer to effectively delegate the numerous responsibilities outlined by the Bank Secrecy Act. Recently, regulators have been taking a much more focused view of how compliance programs are managed. The C3 application can give a compliance manager complete confidence that the most rigid audit by any of the regulatory agencies (or the firm's internal auditor) will meet with success.

C3 IS A TOTALLY UNIQUE COMPLIANCE APPLICATION!

AML best practices call for adequate policies, procedures and controls. However, most compliance failings result directly from inadequate knowledge that a specific policy or procedure is not being followed. C3 provides the control element that will ensure proper management information flow for your firm's policies and procedures.

CLICK HERE FOR A SHORT DEMO OF C3 and ImpactAML services>

There is also a free two week trial available to CheckForRisk, a search engine tool for BSA purposes that knocks the socks off Google, LexisNexis news, and World-Check. And (as they say on TV), that's not all! There is also a HIFCA/HIDTA search tool included that lets you search by counties and zip codes to determine whether a customer is located in either a HIFCA or HIDTA.

So what are you waiting for? Join the ImpactAML community of users and just say no to outrageous BSA compliance costs. Download, use, enjoy -- and stay out of trouble!! (What kind of trouble? See the excerpt from the American Express Bank Assessment of $25 million Civil Monetary Penalty below!) (The checklist was last updated in February 2007)

(The photos below are screenshots of the Checklist's compliance Dashboard. They gives you an idea of the depth of the program's coverage. The third and fourth pictures below are a graphical depiction of the status of a user's checklist progression (zero in this case!), and portions of the Help File index. Reports can also be generated from the data.

The next two pictures below are a graphical depiction of the status of a user's checklist progression (zero in this case!), and portions of the Help File index. Reports can also be generated from the data.

These next pictures show the whole Table of Contents. You can see the incredible amount of information and guidance available to make your independent review easy to accomplish. Everything you need to find to answer the review's items can be found by using the powerful search function!

ImpactAML's BSA Training application combines a video presentation with a training log, subject matter test, and the ability to print certificates for those who receive a passing score.This training satisfies multiple regulatory requirements and will ensure that your employees are well armed with the knowledge they need to comply with BSA mandates. The topics covered in the presentation and accompanying test accomplish these learning objectives:

• Define money laundering and terrorist financing
• Explore the history of anti-money laundering (AML) laws and regulations
• Understand the penalties associated with non-compliance
• Learn what to do to comply with the law

SOME FIRMS CHARGE HUNDREDs AND EVEN UPWARDS OF $1,000 FOR SIMILAR TRAINING COURSES AND PROGRAMS!

Why spend so much when even better quality training is available at a fraction of the cost?
The next time you go to your Chief Compliance Officer asking for a bigger budget, the reason should be to fund a bigger bonus for yourself because of all the money you saved the firm on training! PROGRAM SCREENSHOTS:
Program Dashboard (user interface)

Training Log Report

Certificate of passing grade on the test

ImpactAML's Check Fraud Training application combines a video presentation with a training log, subject matter test, and the ability to print certificates for those who receive a passing score.This training satisfies multiple regulatory requirements and will ensure that your employees are well armed with the knowledge they need to fight fraudsters and those who present financial risk to your operation.

The training will ensure that your front line personnel will:

• Recognize various types of check fraud
• Quickly recognize the look and feel of both good and bad checks
• Understand approaches to recognizing counterfeit checks
• Become familiar with common check security features
• Become familiar with advanced security safeguards and verification techniques
• Be able to identify counterfeit postal money orders
• Be able to identify counterfeit traveler checks

The image below shows the simple user interface to the program:

The images below show how the content is both comprehensive and at the same time clearly presented:


The image below shows a sample from the course's test:

SOME FIRMS CHARGE HUNDREDs AND EVEN UPWARDS OF $1,000 FOR SIMILAR TRAINING COURSES AND PROGRAMS! Why spend so much when even better quality training is available at a fraction of the cost?

Yes, you can use Google to do your due diligence searches. However, you’ll then have to wade through thousands of results in order to get information you can really use.

CheckForRisk returns only relevant search results, which means dramatically less information that is far more useful. Unlike Google or LexixNexis, you don’t have to wade through hundreds of unrelated hits, and unlike World-Check and others, the cost is considerably lower!

Time-to-live is instant, so you know you are searching the latest breaking risk information. Coverage is further enhanced with links to articles from worldwide media. Most importantly, the core collection is re-indexed and updated every 24 hours with new media articles added every hour. CheckForRisk includes a wide range of global risk sources including:

• Anti-Terrorism Watch Lists
• Exchange Enforcement Releases/Sanctions
• Law Enforcement Releases/Sanctions
• Global Most-Wanted Lists
• Identity Theft
• Politically Exposed Persons
• Retail Fraud
• Drug Enforcement Releases
• Credit Card and Check Fraud
• Hacker Arrests and Convictions m

Our last customer, a $100 Billion dollar bank, finished implementing ED³ just last year to meet the terms of a regulatory consent order. We're proud that that order was recently lifted by its regulator.

In short, ED³ provides all the necessary tools needed to delegate EDD compliance responsibilities across the enterprise, while at the same time, tracking and ensuring performance. Full management reporting is available on-screen at just a glance. Keeping track of who needs to be performing specific EDD tasks; what needs to get done and by when; where data is stored; and why accounts are approved for business are all accomplished in one place.

KEY BENEFITS...

• Provides the essential control element needed to determine whether your KYC/EDD policies and procedures are being followed
• Informs management of the status of every time dependent task, such as filing of reports and completion of delegated responsibilities by assigned staff
• Contains a ready reference via the Help File of the most complete and up to date guidance on a wide variety of AML/KYC/EDD concerns and best practices guidelines
• Custom built around your firm's specific KYC/EDD compliance process flows
• Vastly increases the ability to leverage existing MIS (Management Information Systems), as suggested by regulatory agencies
• Demonstrates to regulators, auditors and your Board of Directors that the management of your firm's KYC/EDD compliance program presents minimal operational risk

Other features include:

• Whether the identified activity matches a red flag or profile
• Whether other institutions have filed on the identified activity
• What related criminal activities might be associated with the activity
• The exact Federal criminal statute to use on a SAR form
• ...and much more, all at a glance and within seconds!

If you are wearing many hats and one of those include BSA/AML Investigator, then this application will make your life a whole lot easier. It will also make your investigations and SAR filings as professional as those at the largest firms with dedicated investigator staffs.

Click here to view the product video
Click here to view a quick demo of an alert search

You can see from the table of contents below that there is a wealth of information included in the application - and it's ALL SEARCHABLE.

Just log on to the application from your web browser and enter your secure user name and password. Then, enter all your agents. Your agents will log on and add their employees. Employees will take the training and the included test right over the web. If they pass, a record is entered into the database for your retention requirement and a report can be printed out. The agent can manage all his employees and the Principal can see how all their agents are doing -- whether each agent's employees have taken the training and passed the test and whether their training is current.

This whole enterprise capability is now available starting at just $399 (per year subscription fee) and the cost per employee trained is just about what it costs for a movie ticket! (After the initial fee, your credit card will be charged for each employee only as you add them to the database).

The Main screen (top of this page) gives you instant information regarding the status of all agents as soon as you log in (or employees if logged into the Agent's Screen).

Principals can see all their Agent's and access their training status from a single screen (above).

The Principal's Report (above)screen gives you detail for each Agent's employees' status.

The Agent's Report screen (above)displays the training status for every employee.

The ImpactAML SAR/FIU Module will give you all the knowledge, templates for reports, procedures and investigatory research information that you need to meet FinCENs expectations. FinCEN expects your bank to have processes and procedures in place dealing with:

• Alert & Case Intake
• Case Assessment
• Case Prioritization
• Case Assignment
• SAR Technical and Narrative QC
• SAR Filing, and
• SAR 90 Day Reviews

In fact, Examiners will look at your institution's actual SAR filings as a window into the efficacy of your AML program. Luckily, with ImpactAML's SAR/FIU Module, you've got Windex!

Using this module to our BSA Dashboard, you will easily be able to:

• Produce easy to implement and follow investigations procedures
• Set up investigation case files
• Write complete and acceptable SAR Narratives
• Manage the SAR Filing and Review process
• Decrease the training costs and risks associated with new investigators
• File SARs that meet all FinCEN requirements
• Access up to date guidance and best practices
• Eliminate the risks associated with less formal SAR resolution processes

For the price of this module, you could have attended a conferences in Florida or some webinars and such, and in the end, maybe you come away with some new knowledge, and perhaps a nice tan. What you won't come away with from those conferences and webinars is an executable blueprint for Investigations and SAR procedures that you can implement immediately.

Take a look at the screen shots of the table of contents for the module below and see what you think. Keep in mind that all the content behind those links is context sensitive, making navigation easy and intuitive for what the job is at hand . All the information is also searchable by key words and phrases. For example, need to know what criminal statute to cite on a SAR form for the alert you've investigated? It's about two seconds away! You can also add on the SAR Activity Review Tool and virtually search FinCEN's SAR database for your alert and investigation.

This application is worth the hundreds of thousands of dollars that the big institutions paid for it back when they received their Cease and Desist Orders and such. We should know, because we did the work for many of them! Now, ImpactAML brings all the benefits of a robust SAR and SAR management program to you at a price you cannot afford to pass up.

ImpactAML can now offer this EZ Add-in Module to the BSA Bank Compliance Dashboard for just $995.

Take a look at the table of contents to see the depth of coverage:

ImpactAML has worked to develop procedures and work flows for large financial institutions who have been specifically directed (through various C&Ds, Consent Orders, etc.) to develop manageable Suspicious Activity Investigation programs. We've written policies and procedures and provided direct training for consultants and bank investigators working to resolve alerts as well as conduct extensive look-backs.

Now, for about 1/10,000th of what you might pay consultants for investigations help, training, knowledge transfer, etc., ImpactAML can provide a foundation of information in a 24 minute computer based training video that will allow you to accomplish all of the following:

What the Risk Assessor Software Will Do For You

This application will allow you to risk rate customers who fall into any of several categories of high risk customer types, including:

• Cash Intensive Businesses
• Charities and NGOs
• Money Services Businesses and Private ATM Operators
• Non-Resident Aliens
• Foreign Correspondent Banking Customers
• Senior Foreign Political Figures
• Private Banking Customers
• Generically High Risk Customers (i.e., any categorization that does not fit the above category descriptions)

The Risk Assessor application is flexible and takes into account that the perception of risk varies from institution to institution. It allows you to document your reasoning for including or dismissing items or overriding resulting scores for each customer. This provides exactly what a regulator would need to be shown to validate your whole CDD risk management process!

This application is designed to avoid the most common pitfalls and design flaws of other risk assessment software currently on the market. Most of those applications (besides being just expensive parts of usually bigger AML bloatware) pre-assign a risk level based solely on the customer type. For example, a cash intensive business would be tagged as being high risk solely because it is listed as such in the FFIEC Manual. The problem with such logic is manyfold:

• It ignores the guidance provided by the FFIEC that not all customers of a specific type present the same risk;
• It is directly contrary to the concept of utilizing a risk based approach;
• It assigns risk by broadly generalizing the risk of all customers in a category and does not account for exceptions;
• It does not take into account relevant mitigating factors that may lower risk for a specific customer within a high risk category;
• It artificially enlarges the group of customers for whom you will eventually have to monitor;
• Instead of focusing resources on specific high risk customers, your compliance resources are distributed across a large population of customers, many of whom do not need monitoring at all.

Additionally, many of these programs do not allow the compliance officer to override a calculated risk score and provide a record for the reasons; foster a communications loop between the line-of-business account officer and the compliance office; provide statistical significance for risk calculations, or; allow you to weight factors as you see fit.

Managing Risk

The concept of a Risk Based Approach to anti-money laundering compliance has become the recent mantra of the regulators. One might interpret such an approach as being a common sense application of varying degrees of due diligence steps based upon numerous variables. Yet the fact that the FATF’s recently issued guidance on the topic runs forty-seven (count-em!) pages long (Guidance on the Risk Based Approach to Combating Money Laundering and Terrorist Financing, 2007) suggests that actually implementing such an approach may not be quite as simple as the term itself seems to imply. The FATF, in section 1.12 of its Guidance states that “there are no universally accepted methodologies that prescribe the nature and extent of a risk based approach.”

In the risk based approach schema, the danger is that your approach to risk is not exactly what your regulator has in mind. However, if your approach considers all the relevant risk factors - as defined by the regulatory guidance (FFIEC, etc.), and your approach includes documented parameters and explanations for interpreting and managing risk (e.g., assigning monitoring resources, reviews, etc.) then you are in good stead.

The first step, then, in trying to engineer a risk based approach is to define exactly what risk is and attempt to assign a meaningful descriptive value to the term. If we can assign a value, we can then try to put that value into some useful context to assign monitoring and EDD parameters.

Ultimately though, a risk rating program will only be useful if the underlying data is reliable. Such a program must provide a framework by which to balance the compliance risks and potential profits associated with a high risk customer against the compliance costs and incumbent efforts.

Risk and The Risk Based Approach

Risk is not a bad thing or a good thing. It is simply a measurable value that is interpretable in different ways by different people. For example, two banks might have an identical MSB customer and arrive at the same risk value using this program. But, Bank A might deem the risk of banking that customer too high, whereas Bank B might see the risk of banking that customer as being acceptable. Where the risk value assigned is the same, why might each bank reach a different conclusion?

Well, Bank B might have a larger compliance staff or more sophisticated software to monitor accounts, and thus is able to mitigate parts of the existing risk (as opposed to eliminating the the risks). Or, Bank B might be willing to assume certain levels of risk because of a more aggressive business model than Bank A (i.e., a different risk-to-reward ratio tolerance). While the interpretation of risk will vary, its purpose is constant. In the context of knowing one's customer, a risk measurement:

• Enables a bank to predict the types of transactions in which a customer is likely to engage, thus facilitating the identification of suspicious activities;
• Provides a bank with sufficient information to guide subsequent due diligence and monitoring activities; and,
• Identifies customers for which the risk posed by their activities, backgrounds, sources of wealth, and other factors outweigh the benefit of initiating or continuing a business relationship with them.

Your MSB is required to have a written AML compliance program, or manual. Such a manual should have comprehensive policies and procedures that are customized to the operation of your business.

• Your bank looks to this document as a first step towards deciding whether it will bank you as a customer
• Your regulators view this document as a window into the status of your MSB's compliance culture

If you don't presently have a documented formal anti-money laundering compliance program, then you essentially have three choices...

• First, you can go out and get yourself an expensive lawyer or consultant to draft you such a document for a thousand dollars or more, or....
• Second, you can risk doing without one and hope your bank or regulator doesn't come calling, OR...

....You can use the NMTA AML Program Wizard, be fully copmpliant with an essential PATRIOT Act requirement, keep the regulators happy, AND maintain a good relationship with your bank -- all at a ridiculously low cost that's too good to pass up!

ImpactAML's Compliance Program Wizard is endorsed by the National Money Transmitters Association! This software application will create for you a fully customized, comprehensive AML compliance program. Its easy to use interface will ask you questions about your business operations and then quickly generate a customized Microsoft Word document that will serve as your MSB's AML compliance program manual. The customized manual includes declarations for adopting your AML program, designation of a BSA compliance officer, and other important forms that should be a part of your corporate records. In addition, the software's help file contains detailed resources and guidance pertinent to maintaining your new compliance program. So why wait another minute? Mitigate your regulatory and business risks now with this easy to use software. The expense involved to hire expensive lawyers to write a custom, comprehensive AML Compliance Program is no longer an excuse!! Do it by yourself with help from the Wizard!

WIZARD SCREENSHOTS

The Wizard contains categories of questions. As you complete a category, the button for that category turns green. When all the Wizard's buttons are green, your customized AML Compliance Program Manual is ready to be printed!

The screenshot below is an example of a Question Screen. The Wizard will step you through a series of questions. Your answers will customize your Compliance Manual.

The screenshot below is the Help File contained within the Wizard. As you can see from the Table of Contents at the left, the depth of information available is considerable. If you should need help with any question that the Wizard asks you, the answers are just seconds away by using the Help File's easy to use search feature!

Since many agents and their licensees have internet connectivity issues, or just plain do not want to deal with other than the basics of the training requirement, customers have suggested that we develop a way to train the MSB community in a way that takes the low-tech approach. ImpactAML and the NMTA now offers the same training presentation, test materials, training log and completion certificates contained in the software and online training applications --but in print! When you purchase the NMTA Training Kit (print edition), you may make unlimited copies of all the training materials for distribution to your employees and/or agents. Your policies and procedures can require that certificates of completion be sent back to the licensee or kept on file at an agent location as proof of fulfilling the training requirement. Use the training log for regulatory proof! Employees can take material home to study. The flexibility is ideal for your business and compliance needs!

The cost of the print edition is just $99.95 and it's available in English or Spanish. (Call us for translation costs for other languages.)

So, if your MSB has 25 employees, the cost for training each employee is just $4.00. 100 employees? Just $1.00 each! 1,000 employees? Just $0.10 each. Incredible!

While the software training applications offer certain advantages, the print edition is simple to buy, simple to distribute, simple to manage, simple to use! So, if you've been taking your chances on blowing off the training requirement, ImpactAML and the NMTA have now made training too inexpensive to ignore and avoid. Doing so is now not only a poor compliance decision, but at this price, also a bad business decision!

• Get your people trained now for next to nothing!
• Let your bank know that you take your training requirement seriously and that you are compliant!
• Fulfill one of the major regulatory requirements inexpensively, and
• Reduce your IRS and State Banking Department risks!

While also available in a hardcover print edition, this new e-Book version offers a completely searchable treasure trove of information that will make your SAR process more efficient while reducing compliance risk.

• Imagine being able to match an alert to a known money laundering or terrorist financing red flag in a matter of seconds (This is impossible using FinCEN or other sources, as there is just too much information spread across too many documents.)
• Have an alert concerning a certain business type, e.g., a boat dealer, but unsure if there are any known money laundering profiles associated with such an entity? Just search for "boat dealer" and all of FinCEN's SAR history for such entities is accessible in seconds, properly informing you of your risks! It's like being able to virtually search FinCEN's classified SAR database!
• Have a question concerning specific SAR Form instructions? There are line-by-line instructions for the Form including FinCEN instructions for exceptional reporting items, e.g., natural disaster relief fraud, and many others!
• Need to reference guidance concerning SAR disclosure for special cases (e.g., grand jury subpoenas, NSL's, etc.)? A quick search pulls together the information from over 60 sources, filtered and edited to cut through the noise and bring you the information you need.

Plus.....

• Learn how to tune your transaction alert procedures using simple, fully explained statistical models.
• Learn to become a Google power-user.
• Learn of internet sites that reveal the hidden web and how these sites enable you to conduct quality SAR reviews.
• Learn what quality control steps are necessary before closing or filing an investigation.
• Access a complete Quality Control Investigation list to make sure your investigators/analysts consider all the proper information for every investigation, including cash transactions, customer demographics, network of accounts, and many others!
• Have ready access to complete alert analysis steps for potential structuring, monetary instrument purchases/sales, PICs, wire transfers and many more!

The trial version is available at www.aml-sar.com

The Enhanced Due Diligence Complete BSA/AML Desktop Reference is the book that AML compliance officers have been waiting years for! Finally there is a reference source that combines all the legislation, regulation,and guidance regarding the treatment of high risk customers with industry leading EDD best practices. The electronic edition of the popular hardcover book affords you complete text search capability and ready access to all the EDD information you might need. This reference source contains risk models for most high risk customer types. Learn how you can efficiently risk assess all customers and properly select only those who actually should be subject to EDD. View sample EDD reviews and procedures. Easily check the most current regulations and regulatory guidance for Foreign Correspondent Banking customers, Independent Sales Organizations, Charities, MSBs and many others. Make sure your staff has all the information regarding all the risk factor categories and elements for both "persons" and "entities." Learn how to maximize internet resources when conducting enhanced due diligence. This eBook and ImpactAML's SAR Investigations eBook are the two most downloaded eBooks on the internet. Download your trial copy and see why most professional BSA/AML/EDD financial intelligence units wouldn't be without them!

Finally there is a reference source that brings together all the available guidance and best practices for conducting anti-money laundering suspicious activity investigations!

• Learn how to tune your transaction alert procedures using simple, fully explained statistical models.
• Learn to become a Google power-user.
• Learn of internet sites that reveal the hidden web and how these sites enable you to conduct quality SAR reviews.
• Learn what quality control steps are necessary before closing or filing an investigation.
• Access a complete Quality Control Investigation list to make sure your investigators/analysts consider all the proper information for every investigation, including cash transactions, customer demographics, network of accounts, and many others!
• Have ready access to complete alert analysis steps for potential structuring, monetary instrument purchases/sales, PICs, wire transfers and many more!

There's even information you can use to build customized policies and procedures that address transaction monitoring tuning, alert assignment and reviews and investigations.

You'll find information on all the latest trends identified by law enforcement, including mortgage loan fraud, bulk cash smuggling, pretext calling, and many more.