Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Source of Funds • KYC Program should be established o Include: • How information is obtained • How it is verified • How it is retained • How it is secured (who has access) • How often it will be updated • At least annually
17
OFAC • Office of Foreign Assets Control:
• Specially Designated Nationals (SDNs)
18
BlueBird, CPAs
9
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