Ethics of Money Laundering Regulations
Anti-Money Laundering Training Course
Table of Contents
Section 1 — What is Money Laundering?
- Section 1956 of Title 18
- Specified Unlawful Activity
Section 2 — How Money is Laundered
- Placement
- Layering
- Integration
Section 3 — Suspicious Activity and Terrorist Financing
- Signs of Money Laundering
- Types of Behavior
- Filing an SAR
- Transactions Requiring Filing an SAR
Section 4 — Regulatory and Enforcement Framework against Money Laundering
- Bank Secrecy Act of 1970
- Reports/Registrations Required by the Bank Secrecy Act of 1970
Section 5 — NFA Compliance Rule 2-9
- Anti-Money Laundering Program Minimum Requirements
- Interpretive Notice #9045
Section 6 — Recognizing and Reporting “Suspicious Activity”
- Hiring Qualified Staff
- Record Keeping
Section 7
- Designation of a Compliance Officer
- Employee Training Program
- Independent Audit Function
- Sanctions for Money Laundering
- Violations of Section 1956(a)(1) and 1956(a)(2)
Section 8
- Asset Forfeiture
- Burden of Proof
- Court-Appointed Legal Representation
- “Innocent Owner” Defense
- Substantial Hardship
- Payment for Damage to Improperly Seized Property
- Fitting the Punishment to the Crime
- Real Estate Forfeiture
- Use of Criminal Forfeiture
- Use of Civil Forfeiture
Section 9
- Penalties for Failure to Report as Required
- Suspicious Activity Report (Form SAR)
- Currency Transaction Report (Form CTR)
- Report of International Transportation of Currency or Monetary Instruments (CMIR, Form 4790)
- Foreign Bank and Financial Accounts Report (FBAR, Form TD F 90-22.1)
Section 10
- Report of Cash Received in a Trade or Business (Form 8300)
- Reports Pursuant to Geographic Targeting Orders
- Registration as a Money Services Business (Form TD F 90-22.55)
Conclusion
- Long-Term Consequences of U.S. Money Laundering Legislation