Include a system of internal controls to assure ongoing compliance; provide for independent testing for compliance; designate an individual responsible for coordinating and monitoring day-to-day compliance; and provide training for appropriate personnel.
Establish effective customer due diligence systems and monitoring programs
Screen against Office of Foreign Assets Control (OFAC) and other government lists
Establish an effective suspicious activity monitoring and reporting process
Develop risk-based anti-money laundering programs
Customer Due Diligence (CDD) and Customer Identification Program (CIP) Programs
Keep records of cash purchases of negotiable instruments,
File reports of cash transactions exceeding $10,000 (daily aggregate amount),