We are a state regulated non-bank institution.
§ 103.170 Exempted anti-money laundering programs for certain financial institutions. (2) Subject to the provisions of paragraphs (c) and (d) of this section, a bank (as defined in §103.11(c)) that is not subject to regulation by a Federal functional regulator (as defined in §103.120(a)(2)) is exempt from the requirement in 31 U.S.C. 5318(h)(1) concerning the establishment of anti-money laundering programs...
Believe me, I do not think we are truly exempt from an AML compliance program, as we are required to have a written CIP program, OFAC, training, BSA Officer, etc.