Thread Starter: Anonymous
Title: Re: State of Mass. Regulated Bank and SAR
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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.
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