Patriot Group Task Force
Members:  Association of Certified Anti-Money Laundering Specialists

Catalog of AML Programs and Support Services 
How can we establish the right AML programs for our company,
quickly and without diverting key managers from their work? 

The Patriot Group Task Force programs are geared to the precious metals industry, the precious stones and the jewelry business, and coin dealers.  We scale programs to your company size, laundering risk and regulatory exposure--affordably and without disrupting your systems and staff.  And we provide advisory services to help you plan, evaluate and reinforce your AML program.

The Task Force will provide you with a complete anti-money laundering program or the individual components you need, including:  

1. RISK ASSESSMENT SOFTWARE Ó â1
2. ANTI-MONEY LAUNDERING PLAN: WRITTEN POLICIES & PROCEDURES Ó  
3. CUSTOMER IDENTIFICATION PROGRAM Ó â2
4. CUSTOMER IDENTIFICATION PROGRAM FLOWCHART
5. SEARCH ENGINE FOR GOVERNMENT LISTS
6. ANTI-MONEY LAUNDERING TRAINING:
    A. On-Site Training
    B. Sales Persons’ and Managers’ Course Ó
    C. Compliance Officer and Senior Manager Course Ó   
    D. "Red Flags" Course Ó
    E. AML Poster Ó
7. AUDIT PROGRAMS:
    A. Internal Audit Software â1
    B. External Audit Service
8. DUE DILIGENCE REVIEWS

1. RISK ASSESSMENT SOFTWARE
The first step in our anti-money laundering program is to assess your risk. You and your management need to know:

a. Your company's exposure to money-laundering risk.
b. How your AML program is performing to reduce that risk.

Our risk-assessment software will help you gauge your company’s exposure—easily and accurately. You need to know just where in your business the risks are the greatest. Location, size, customer history, payment method, money transfers, detection capability, training—these are some of the components of your risk profile.

A built-in scoring system provides a convenient index to measure the company’s risk and evaluate the effectiveness of your AML program. Each time you complete the electronic questionnaire, you leave a marker of your progress toward a compliance level appropriate to your company.

Cost: $750.     Top

2. ANTI-MONEY LAUNDERING PLAN: WRITTEN POLICIES & PROCEDURES
Are your internal policies, procedures and controls spelled out (in detail) to show how you plan to detect and prevent money laundering...and comply with the USA PATRIOT Act? Enforcement agencies can require you to produce your written program at any time. Without it, you risk severe civil penalties.

The Patriot Group Task Force will provide you with a fully-compliant, comprehensive, written AML program geared specifically to your company’s requirements and capabilities. You will have it promptly and it will save you legal fees and weeks of time, research and writing.

Here are the steps:

    1. We spend time with you to understand your company and its exposure to money-laundering.
    2. We prepare a draft based on our interview. While meeting Government standards, your program must recognize the  limits of your company’s capabilities. After you review the draft,
    3. We provide you with a written plan of policies and procedures to detect and prevent money laundering, customized to fit your compliance and enforcement needs.

During the next year, we expect there will be amendments and adjustments to the regulations and will update your program free of charge.

Cost: We will give you a firm estimate before beginning work on your company’s program,     Top

3. CUSTOMER IDENTIFICATION PROGRAM
The Customer Identification Program software is an archive and retrieval facility consolidating all the customer information you collect to protect yourself against money laundering. It is specially geared to the industry and designed to:

Collect complete information.
Make entries quickly and error-free.
Search and retrieve information readily.
Evaluate the money-laundering risk associated with each customer.

It should pay for itself the first year in audit expenses saved.

At a Glance: The "Entry" page displays basic information about the customer (account number, name, and location). It also calculates the customer’s risk evaluation score, the amount of information collected and how much has been checked. It alerts you to missing documents, pending events, expiration dates and deadlines.

The AML Compliance Officer can retrieve details of supporting documents such as business licenses, financial statements, photographs, spreadsheets and other scanned items. Documents can be embedded in the Program or linked to it. Free-form textboxes let you jot notes and comments and retrieve them instantaneously. And you can save search patterns to apply the same criteria to any or all your accounts.

Risk-based Organization: Information is divided into tiers, ranging from data required for all customers to information needed for only the largest or most risk-laden:

Tier I includes the information required by the USA PATRIOT Act to identify a customer, its customer’s beneficial owner and authorized parties along with verification items, such as a business license, and non-documentary information, such as bank references. Tier I information is required, whereas Tier II and Tier III information are discretionary. So, Tier I information is scored in its entirety for quality and comprehensiveness of information.

Tier II covers additional information you will want for many of your customers. It includes how long you have known the customer, how the customer came to the company, nature of business, basic financial information, metals or stones traded, anticipated volume, locations and other information.

Tier III is for large customers or customers presenting high money-laundering risk. This includes a complete listing of beneficial owners, officers, directors and other interested parties, along with identifying information, company financial statements and credit agency reports.

Scoring Information: The Customer Identification Program scores accounts by the thoroughness of screening and by the quality and completeness of customer information. The total raw score is adjusted by the number of fields checked to make account evaluations comparable.

Security: The Customer Identification Program is password protected. Sensitive information can be restricted by additional password layers, and the program can be covered by read-only access.

Data Entry: Data can be entered into the Customer Identification Program easily (i) from your existing accounting and control program, (ii) from information you obtain by fax or phone, or (iii) from an electronic worksheet that your customer completes on the internet for you to check and download directly into the Customer Identification Program. Prompts and drop-down menu’s help make entries quick and error-free.

Data Access/Transfer: It’s important to be able to transfer files quickly within your company, to share files and data with your parent company or among affiliates, to respond to an auditor for testing or to comply with Government requests. A click of a button lets you e-mail complete files or individual documents. Transferred files are protected against alteration.

Compatibility: You can import data into the Customer Identification Program from an external data base or export it via comma-delimited format into an Excel worksheet, MS Access or other popular applications. Fields are formatted to provide maximum flexibility to the user.

Please contact us for a CD showing how the Customer Identification Program works.

Cost: $5000 (including 50 electronic worksheets).     Top

5. SEARCH ENGINE FOR GOVERNMENT LISTS
The Act requires that you check customers against Government lists of companies and individuals involved in money-laundering and terrorist finance. The lists can be voluminous and complicated by duplications, coincident names, spelling variations and AKA’s.

With our search engine, you can enter an individual’s or company’s name and check for a match immediately on eight different lists. If you use Google, you will be comfortable using our search engine.

Cost: $100 a month or $1000 a year.     Top

6. AML TRAINING
The safety of you company depends on how well you train your staff to recognize, prevent and respond to money laundering. For the company and the employee, unwitting involvement is just as devastating as willful participation. The law requires initial training and continuing education.

    A. On-Site training courses
We offer both face-to-face group courses and online interactive training. On site training can include any of the course materials in our online interactive courses (shown below), or we can design training specifically for your company. Some of our customers prefer an initial "live" presentation to accommodate questions in an informal exchange. They then use our online training courses to expand and reinforce the initial group session and to satisfy continuing education requirements. Please contact us to learn more about our on-site courses.

Cost: Hourly/per diem.     Top

    B. Sales Persons’ and Managers’ General Course
Employees dealing with customers and any employee needing a general AML background should take this course. The general course is particularly well-suited to train new employees.

By taking the course, employees will come away with a working knowledge of:

How money-laundering works,
The USA PATRIOT Act’s place in the anti-money laundering statutes,
The Act’s scope and regulations,
Consequences of violation,
Customer information requirements,
Red flags,
Responding to law enforcement investigations, and
Reporting requirements.

Participants take the course online at their convenience--anywhere, anytime--wherever there is a PC. It is interactive, with review questions throughout. It takes about 45 minutes to complete. After completing a quiz, the participant receives a certificate confirming completion. We e-mail you a copy for your records to confirm the date and nature of the training.

Cost: First five participants, $100 a person; thereafter, $75     Top

    C. AML Compliance Officer and Senior Manager Course
AML Compliance Officers, senior managers and Board members involved in the AML program need an in-depth understanding of money-laundering and terrorist finance, the regulatory requirements, and how to interact with Government enforcement agencies.

This course provides that preparation. It is introductory yet comprehensive; interesting and yet detailed in its coverage. The course will give you a working knowledge of:

The AML Compliance Officer’s duties under the USA PATRIOT Act of 2001,
Why the Act has been extended to precious metals, stones and jewels,
Risk assessment requirements and expectations,
What information is needed in a Customer Identification Program,
How to check risk factors: OFAC list, restricted locations and size,
How to monitor for suspicious activity Red flags and alerts,
How and where to report suspicious activity,
Reporting under the Bank Secrecy Act,
Precious metals pool accounts,
Record keeping requirements,
How to respond to Treasury,
Department requests for information,
Training requirements,
Audit requirements.

With the General course, which we recommend you take first, the AML Compliance Officer Course establishes the foundation on which to build a solid AML program. It will also give senior managers and board members the comprehensive background they need.

The course is given online, so participants can take it as time permits. The course is interactive and filled with case studies. Participants are urged to note questions, comments and observations so they can be discussed one-on-one with one of our Certified Anti-Money Laundering Specialists. A certificate of completion is awarded upon completion, with a copy emailed to the employer for its records.

Cost: $500 (Including the General Training Course).     Top

    D. AML "Red Flags" Course
No matter how comprehensive your AML program and no matter how diligent its implementation, it will be without substance if employees are not alert to money-laundering signals. This course underscores the importance of vigilance, the signs to watch for, and how to respond. It summarizes:

Money-laundering risk,
Red flags to which you should be alert,
Reporting requirements,
Willful blindness,
How to respond.

AML training is most effective if reinforced. In addition to an in-depth treatment of money-laundering signals, the AML "Red Flags" Course is designed to follow and reinforce the AML Sales Persons’ and Managers’ General Course.

Participants take the course online, at their convenience, wherever there is a PC. It is interactive, with review questions throughout and a quiz at the end. It takes about 25 minutes to complete. After completing a quiz, the participant receives a certificate confirming completion. A certificate is also emailed to you, the employer, to confirm the date and nature of the training that took place.

Cost: First five participants, $100 a person; thereafter, $75.     Top

    E. AML Poster & Handouts
For many employees, you may wish to heighten awareness even though their customer contact does not warrant formal training. We provide an attractive poster that states your AML policy, encapsulates the regulations, explains the consequences of even incidental involvement in a money-laundering scheme and tells employees whom to contact if they come upon suspicious activity. The poster is reinforced with individual handouts. From a regulatory standpoint, this poster covers employees who might otherwise gain no exposure to your AML program and policies.

Cost: $35 per poster with handouts.     Top

7. AUDIT PROGRAMS
Do you have an independent audit function in place to review and test the implementation of your due diligence program? The Act requires you to test your AML systems. Testing must be by an independent internal or an external auditor. The Patriot Group Task Force can help with either alternative.

    A. Audit Software for Internal Audits
The Patriot Group Task Force's Audit Software guides the auditor through each phase of an AML program as he or she completes testing. It will save days, perhaps weeks of your time. The software is based on a comprehensive electronic "check list." Some questions call for one-word or multiple choice answers; others require written analysis, evaluation and conclusions. The program indexes your written notes, work papers and analysis to each question. Notes are in MS Word format--simple to convert into a report or a PowerPoint presentation. Archive audits to compare your testing year-to-year.

An electronic Management Letter--free with the program--helps you summarize and present your conclusions.

Cost: $2000.     Top

    B. External Audit Service
If you prefer to have your testing done by an external auditor, the Patriot Group Task Force auditors are uniquely qualified. They are Certified Anti-Money Laundering Specialists (CAM’s) and also have industry backgrounds in precious metals and stones. You can count on an audit that is comprehensive, speedy and within your budget.

Cost: Based on size and complexity of testing. We will give you an estimate at the outset.    Top

8. DUE DILIGENCE REVIEWS
If you would like to confirm the quality or comprehensiveness of your anti-money laundering programs, one of our Certified Anti-Money Laundering Specialists will review your written plan or any part of your due diligence procedures.  

Cost: We will give you an estimate at the outset.      Top

ã    Copyright 2004. 
â1 Patent Pending, 2004
â2 2 2 Patent Pending, 2003