ACAMS Today Magazine (March-May 2011) Vol. 10 No. 2 | Page 16

AML CHALLENGES issuer to maintain separate areas or departments, one to develop and train on the AML requirements and one to perform independent testing for compliance. also include assessment of the risks associated with offering the products through third parties. The April 2010 FFIEC BSA/AML Examination Manual provides a good outline of the risk mitigation factors to consider. Each program manager should have a designated AML officer AML policy In addition to ensuring that its enterprisewide AML Program covers issuance of prepaid, the issuer should also have documented AML requirements to which its program managers are contractually required to comply. These requirements should include the issuer’s expectations for the program manager’s AML policy, four pillars and specific requirements for CIP, transaction monitoring, reporting, and OFAC. Depending on the program manager’s other business lines, program manager’s may or may not be required to have their own AML policy to address applicable AML regulations. In those cases, the sale of prepaid cards and the issuer’s requirements should be added to program manager’s existing AML policy. AML officer Each program manager should have a designated AML officer. Depending on the size of the company, the officer may hold multiple positions, including but not limited to legal, fraud, risk, finance or operations. In all cases, the program manager’s AML officer should have the resources needed to fulfill their responsibilities; however, the AML officer may have limited AML experience depending on the program manager’s other business lines. In those cases, it is beneficial if the issuer can provide additional training. Offering the program manager industry training solutions, such as those provided by the Network Branded Prepaid Card Association (NBPCA)2 or ACAMS, can be beneficial for everyone. AML training and retail agents Program managers should be required to attend initial and annual training on the issuer’s AML requirements. The program manager should also be required to provide AML training to their applicable staff and any retail agents. If the program manager is using retail agents to sell ܈