Recommendations in our review of Lake Como 2015 AML Review
Regarding the test results of the employees' training, test scores, Lake Como should ensure, that the subject matter of those incorrect test questions, the company should obtain additional reading material on those subject matters where the employees need more knowledge
Highlight the additional new procedures incorporated in the 2015 AML Manual, using a different color text addressing the 2014 recommendations on possible structuring events
The company should address in its manual how the company’s defines an active or inactive customer and ensure consistently applies the definition within each reporting annual period.
When creating the company's mater list of customers, the compliance …show more content…
This report should demonstrate the delta (x %) in a change of CTR’s and SAR’s activities to the total population and illustrate a pattern or direction on how and why the company’s AML risk is changing.
With respect to monitoring for possible structuring events, the compliance officer should document using written notes as to how he decides whether to file certain possible structuring events. The decision should always mention the basic key elements used as factors in his decision process. His review of certain events on possible structuring, he should list the following common attributes as factors in his decision process:
1) The number of times a customer conducts a transaction over a certain dollar amount “the so called Threshold amount” just under $10,000.
2) The maker of the checks from the customers.
3) The date(s) of the checks written followed by
4) The check number of the checks used in the
Regarding the test results of the employees' training, test scores, Lake Como should ensure, that the subject matter of those incorrect test questions, the company should obtain additional reading material on those subject matters where the employees need more knowledge
Highlight the additional new procedures incorporated in the 2015 AML Manual, using a different color text addressing the 2014 recommendations on possible structuring events
The company should address in its manual how the company’s defines an active or inactive customer and ensure consistently applies the definition within each reporting annual period.
When creating the company's mater list of customers, the compliance …show more content…
This report should demonstrate the delta (x %) in a change of CTR’s and SAR’s activities to the total population and illustrate a pattern or direction on how and why the company’s AML risk is changing.
With respect to monitoring for possible structuring events, the compliance officer should document using written notes as to how he decides whether to file certain possible structuring events. The decision should always mention the basic key elements used as factors in his decision process. His review of certain events on possible structuring, he should list the following common attributes as factors in his decision process:
1) The number of times a customer conducts a transaction over a certain dollar amount “the so called Threshold amount” just under $10,000.
2) The maker of the checks from the customers.
3) The date(s) of the checks written followed by
4) The check number of the checks used in the