At a minimum, dealers must establish an anti-money laundering program that comprises the following four elements:

• • Policies, procedures and internal controls, based on the dealer’s assessment of the money laundering and terrorist financing risk associated with its business;
  • A compliance officer who is responsible for ensuring that the program is implemented effectively;
  • Ongoing training of appropriate persons concerning their responsibilities under the program; and
  • Independent testing to monitor and maintain an adequate program.

The Consultants are able to walk you through creating and maintaining all the requirements of an AML program.