Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Common Issues #10 No/inadequate risk assessment performed #9 Compliance program not based on risk o Superficial, FinCEN only regulations #8 No KYC or Source of Funds program #7 MTL entries o Transactions not logged
o Lack of adequate description of unknown patrons (or known)
25
Common Issues #6 MIL entries
o Missing information o Transactions not logged #5 Inadequate or non-existent training #4 Lack of documentation regarding date of notification for filed SARs
26
BlueBird, CPAs
13
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