NBFI BSA/AML Program

I have a customer who is an NBFI (they lend funds to customers to purchase gas stations) and they do not have a BSA/AML Program and don't seem to know anything about it. I have an excerpt from FFIEC that I am going to share with them but does anyone have any excellent resources that I can share with our customer to show how to create this document and that they are required to provide it to us? I have been doing some of my own searching but nothing seems to be really good to me.

When their regulator does not like it they will come back to you. Give them the FFIEC stuff and let them run with it.