Newsletters & Alerts
Compliance deadline looms for mortgage lenders to establish anti-money laundering programs
In February of 2012, the Financial Crimes Enforcement Network (“FinCEN”) issued final regulations requiring non-bank residential mortgage lenders and originators to establish anti-money laundering (“AML”) programs and file suspicious activity reports (“SARs”), as FinCEN requires of other types of financial institutions (the “Non-Bank AML/SAR Rules”).
Compliance must take effect beginning August 13, 2012.
As a result of the Non-Bank AML/SAR Rules, mortgage lenders and originators, for the first time, will be required to establish AML programs and file SARs with FinCEN.
Failure to comply with the Non-Bank AML/SAR Rules could subject mortgage lenders and originators to a range of civil and criminal penalties.
As a result of the foregoing, mortgage lenders and originators should consult their legal counsel to determine whether their compliance strategy is sufficient to satisfy their obligations under the Non-Bank AML/SAR Rules.
Read a copy of the Non-Bank AML/SAR Rules.
This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.
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