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The Anti-Money Laundering (AML) Program form serves a crucial role in ensuring compliance with federal regulations designed to combat illegal financial activities. Developed by the George Washington University, this form is overseen by the Senior Associate Vice President for Finance and originated in October 2005, with its last amendment occurring on June 26, 2014. The policy emphasizes the university's commitment to adhering to various laws, including the Money Laundering Control Act of 1986, the Bank Secrecy Act, and the USA PATRIOT Act of 2001. It aims to enhance protective measures against money laundering and terrorist financing while minimizing the risk of university resources being misused. The policy outlines who needs to be aware of these regulations, mainly faculty, staff, and students, fostering a culture of vigilance and compliance. Key features of the AML program include procedures for verifying customer identities, the establishment of a dedicated compliance officer, and protocols for reporting suspicious activities. Training initiatives ensure that university personnel understand their responsibilities, while independent reviews maintain the program's effectiveness. Contacting the Treasury Management Office is essential for anyone noticing unusual financial transactions. Overall, the form is a vital tool in promoting transparency and integrity within the university’s financial dealings.

Aml Program Example

Responsible University Official:

Senior Associate Vice President for

Finance

Responsible Office: Treasury

Management

Origination Date: October 2005

Last Amended Date: June 26, 2014

ANTI-MONEY LAUNDERING POLICY

Policy Statement

It is the policy of the George Washington University to comply with anti-money laundering obligations imposed by the federal government, including applicable provisions of the Money Laundering Control Act of 1986, the Bank Secrecy Act, the USA PATRIOT Act of 2001, the rules and regulations overseen by the United States Treasury Department’s Office of Foreign Assets Control and Financial Crimes Enforcement Network, and other legal requirements.

Reason for Policy/Purpose

The purpose of this policy is to enhance the university’s compliance with anti-money laundering laws and regulations, to assist law enforcement in combating illegal money laundering, and to minimize the risk of university resources being used for improper purposes. Failure to comply with anti-money laundering regulations could result in civil and criminal penalties to the university and/or individual faculty, staff and students.

Who Needs to Know This Policy

 

Faculty, staff, and students

 

Table of Contents

Page #

Policy Statement

1

Reason for Policy/Purpose

1

Who Needs to Know This Policy

1

Table of Contents

1

Policy/Procedures

2

Website Address for This Policy

2

Contacts

2

Related Information

3

Who Approved This Policy

3

History/Revision Dates

3

ANTI-MONEY LAUNDERING POLICY

Policy/Procedures

Money laundering is conducting or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activity. To assist the federal government in detecting, preventing, and eradicating criminal and terrorist financing and activity, the university will take all necessary steps to comply with applicable anti-money laundering laws and regulations.

The university will maintain an anti-money laundering program in accordance with the Bank Secrecy Act, as amended by the USA PATRIOT Act, and other applicable federal laws and regulations. The program is reasonably designed to prevent university services from being used to facilitate money laundering and the financing of terrorist activities. The program includes the following:

Procedures to verify customer identification and retain necessary identifying and transactional information;

A designated compliance officer to coordinate compliance with the program;

Suspicious activity reporting procedures and document retention guidelines for any suspicious activity reports and supporting documentation;

Training and education of appropriate university personnel concerning their responsibilities under the program, including suspicious activity reporting; and

Independent review to monitor and maintain an adequate program.

Concerns regarding transactions that are unusually large or that appear suspicious and questions regarding money laundering in general should be directed to the university’s Treasury Management Office at 202-994-0985.

Website Address for This Policy

GW University Policies

Contacts

Subject

Contact

Phone

Money

Treasury Management

703-726-4216

Laundering

 

 

2

ANTI-MONEY LAUNDERING POLICY

Related Information

Bank Secrecy Act, 12 U.S.C. §1951, et seq.

31 U.S.C. § 5311, et seq.

31 C.F.R. Part 1010, 1022

Money Laundering Control Act of 1986, Public Law 99-570 USA PATRIOT Act of 2001, Public Law 107-5

A Brief Primer on Doing Business Abroad: U.S. Laws that Affect GW’s International Activities

Compliance with Law when Conducting University Activities Overseas

Who Approved This Policy

Louis H. Katz, Executive Vice President and Treasurer

Beth Nolan, Senior Vice President and General Counsel

History/Revision Dates

Origination Date:

October 2005

Last Amended Date:

June 26, 2014

Next Review Date:

June 30, 2015

3

Form Characteristics

Fact Name Description
Responsible University Official Senior Associate Vice President for Finance oversees anti-money laundering compliance.
Responsible Office The Treasury Management office is tasked with implementing the anti-money laundering program.
Origination Date The anti-money laundering policy was first established in October 2005.
Last Amended Date This policy was last amended on June 26, 2014.
Governing Laws The policy is governed by the Money Laundering Control Act, the Bank Secrecy Act, and the USA PATRIOT Act.
Purpose of Policy The policy aims to enhance compliance with money laundering laws and assist in law enforcement efforts.
Who Needs to Know Faculty, staff, and students are all informed of this policy.
Compliance Measures Measures include customer identification verification, suspicious activity reporting, and training of personnel.
Review Schedule The next review of the policy is scheduled for June 30, 2015.

Guidelines on Utilizing Aml Program

After you have gathered the necessary information for the AML Program form, follow these steps to fill it out properly. Ensure all required details are accurate and complete to avoid any compliance issues.

  1. Start by entering the Responsible University Official at the top of the form. This should be "Senior Associate Vice President for Finance."
  2. Provide the name of the Responsible Office, which is "Treasury Management."
  3. Fill in the Origination Date as “October 2005.”
  4. Enter the Last Amended Date as “June 26, 2014.”
  5. In the next section, outline the Policy Statement. You can paraphrase or summarize the key points about compliance with anti-money laundering obligations.
  6. For the Reason for Policy/Purpose section, briefly describe the policy’s purpose and consequences of non-compliance.
  7. Include a list of individuals who need to know this policy: faculty, staff, and students.
  8. Next, for the Policy/Procedures section, describe the protocol for preventing and reporting suspicious activities.
  9. List all the elements of the anti-money laundering program as mentioned, emphasizing customer identification, compliance officer, suspicious activity reporting, training, and independent review.
  10. Lastly, provide the Contacts information, ensuring that the necessary contact details for Treasury Management are included clearly.

What You Should Know About This Form

What is the Aml Program form?

The Aml Program form outlines the George Washington University’s policies and procedures for complying with anti-money laundering laws. Established to prevent laundering activities, it emphasizes the responsibilities of faculty, staff, and students in detecting and reporting suspicious activities.

Who is responsible for the Aml Program?

The Senior Associate Vice President for Finance oversees the Aml Program. They ensure compliance with anti-money laundering obligations and coordinate training and procedures within the university.

What are the key components of the Aml Program?

The Aml Program includes several crucial elements, such as procedures for verifying customer identification, guidelines for suspicious activity reports, and the training of university personnel. An independent review mechanism is also in place to monitor compliance and effectiveness.

Why does the university have an Aml Program?

This program aims to comply with federal anti-money laundering laws, enhance law enforcement efforts, and reduce the risk of university resources being misused. Non-compliance could lead to serious penalties for the university and individuals involved.

Who needs to be aware of the Aml Program?

All faculty, staff, and students at George Washington University should be aware of the Aml Program. Understanding its requirements helps ensure compliance and safeguards against potential illegal activities.

How can someone report suspicious activities related to money laundering?

Any concerns regarding suspicious transactions should be reported to the university’s Treasury Management Office at 202-994-0985. Prompt reporting can help prevent and address suspicious activities effectively.

What happens if the university fails to comply with anti-money laundering laws?

Failure to comply with these laws can result in both civil and criminal penalties. This could affect the university’s financial standing and put individuals at risk of legal consequences.

Where can I find more information about the Aml Program?

Additional information about the Aml Program, including policy details and related resources, can be found on the George Washington University policies website. For specific inquiries, contact the Treasury Management Office.

Common mistakes

When filling out the AML Program form, many individuals make mistakes that can lead to complications. One common mistake is overlooking essential identification requirements. Detailed information about customer identification must be provided. Forgetting to include proper documentation can result in delays or a rejected form, so it’s crucial to understand exactly what is needed.

Another frequent error involves inadequate understanding of suspicious activity parameters. Those completing the form often fail to recognize what constitutes suspicious activity. This oversight can lead to improper reporting and potential penalties. A comprehensive review of the definitions provided within the policy can prevent such misunderstandings.

People also tend to neglect training and education requirements outlined in the policy. The AML Program form requires that appropriate university personnel receive training, yet some may not provide proof that this has been completed. Without adequate training, key responsibilities in identifying and reporting suspicious activities may not be met.

Some individuals rush through the reporting procedures section, leading to inaccurate submissions. This area requires careful attention because proper procedures must be followed to ensure compliance with regulations. Failing to provide the necessary details can create compliance issues down the line.

Additionally, misunderstanding the role of the compliance officer can pose challenges. The form specifies that a designated compliance officer must coordinate the program’s adherence. When this role is unclear, organizations may experience lapses in oversight, potentially leading to regulatory violations.

We often see individuals neglecting to maintain thorough documentation of suspicious activity reports and supporting evidence. Proper record-keeping is essential for compliance and future reference. An inability to provide adequate documentation may hinder investigations or audits, resulting in negative consequences for the university.

Lastly, many fail to update contact information or neglect to provide necessary approvals. The form is subject to revisions, and ensuring that all contact details and approval signatures are current can prevent confusion. Keeping this information up-to-date is necessary to facilitate smooth communication and compliance efforts.

Documents used along the form

The use of the Anti-Money Laundering (AML) Program form is often accompanied by additional documents that support compliance and regulatory measures. Understanding these documents can provide clarity on the university's comprehensive approach to anti-money laundering policies.

  • Customer Identification Program (CIP): This document outlines procedures for verifying the identities of individuals or entities engaging in financial transactions. Compliance with the CIP is crucial to prevent fraudulent activities and ensure that the university knows its customers.
  • Suspicious Activity Report (SAR): This form is used to report any transactions that appear suspicious or trigger concerns about potential money laundering or terrorist financing. Filing a SAR is a legal obligation for institutions when certain thresholds or indicators are met.
  • Compliance Officer Designation: This document officially identifies an individual responsible for overseeing the AML program's implementation and ensuring adherence to relevant laws. The designated compliance officer plays a vital role in training, monitoring, and reporting within the program.
  • Training Documentation: Evidence of training sessions conducted for university employees on AML practices and procedures. This documentation shows the commitment to a compliant culture and keeps personnel informed about their responsibilities regarding anti-money laundering measures.

Collectively, these documents reinforce the university's efforts to mitigate risks associated with money laundering and to comply with federal guidelines. They serve as key tools in the establishment of a robust AML framework.

Similar forms

The Anti-Money Laundering (AML) Program form shares similarities with various other documents that govern compliance and risk management in financial and higher education institutions. Below is a list of key documents with comparative explanations.

  • Compliance Program Manual: Like the AML Program, this document outlines the institution's commitment to regulatory compliance. It identifies responsibilities, processes, and reporting structures to prevent violations of laws and regulations.
  • Risk Management Policy: This policy, similar to the AML Program, aims to identify, assess, and mitigate risks. Both documents emphasize proactive measures to prevent organizational vulnerabilities.
  • Fraud Prevention Policy: Parallel to the AML Program, this policy establishes measures to detect and prevent fraudulent activities. Both documents highlight the importance of training and reporting suspicious activities.
  • Ethics Policy: This document outlines the institution's standards of conduct. Similar to the AML Program, it establishes expectations for behaviors that minimize risk and safeguard the institution's integrity.
  • Financial Auditing Procedures: This set of guidelines assists in ensuring accuracy and compliance in financial reporting. It shares similarities with the AML Program in its focus on transparency and accountability.
  • Gifts and Donations Policy: Like the AML Program, this policy regulates the acceptance and reporting of funds. It seeks to prevent illegal funding sources and promotes ethical financial practices.
  • Data Privacy Policy: This policy governs the handling of sensitive information, akin to the AML Program's emphasis on safeguarding customer identification information relevant to financial transactions.
  • Conflicts of Interest Policy: This document outlines procedures to avoid conflicts that might harm the institution. Similar to the AML Program, it establishes reporting mechanisms for potential issues.
  • Security Incident Response Plan: This document addresses protocols in case of security breaches. Like the AML Program, it stresses the need for swift action and reporting processes to mitigate damage.
  • Training and Development Policy: This policy details how employees will be educated about compliance and risk areas. It is similar to the AML Program in its focus on the training of personnel to recognize and report issues.

Dos and Don'ts

  • Do read the entire form carefully before starting to fill it out.
  • Do provide accurate and up-to-date information.
  • Do check for any required documentation that needs to be submitted with the form.
  • Do keep a copy of the completed form for your records.
  • Don't leave any sections blank unless instructed to do so.
  • Don't use technical jargon or abbreviations that may not be universally understood.
  • Don't rush the process; take your time to ensure accuracy.
  • Don't share sensitive information without understanding why it is needed.

Misconceptions

  • Misconception 1: The Aml Program form is only relevant for large institutions.
  • This form is important for any university, regardless of size. Even smaller institutions must ensure compliance to prevent any potential misuse of funds.

  • Misconception 2: Compliance is solely the responsibility of the compliance officer.
  • While the compliance officer plays a crucial role, all faculty, staff, and students are responsible for understanding and following the policy. Everyone has a part in identifying suspicious activity.

  • Misconception 3: The Aml Program is only about preventing money laundering.
  • The program also focuses on combating terrorism financing. It aims to protect the university from being an unwitting participant in illicit activity, including terrorism-related financing.

  • Misconception 4: Reporting suspicious activity is optional.
  • Reporting is not just encouraged but required. Addressing unusual transactions helps protect the university and can aid law enforcement efforts significantly.

Key takeaways

Filling out and utilizing the Aml Program form effectively is crucial for ensuring compliance with anti-money laundering regulations. Here are some key takeaways to keep in mind:

  • Understand the Importance: This policy helps the university meet federal anti-money laundering obligations, minimizing the risk of misuse of university resources.
  • Training is Essential: Personnel must be educated about their responsibilities under the program, including how to report suspicious activities.
  • Designated Compliance Officer: A specific official oversees compliance. Contact them if you have concerns about large or suspicious transactions.
  • Document Everything: Maintain records related to customer identification, suspicious activity reports, and training sessions to fulfill legal requirements.

By adhering to these key points, you help protect the university and its community from the risks associated with money laundering activities.