ANTI-MONEY LAUNDERING (AML)POLICIES & PROCEDURES MANUAL

INSTRUCTION: Please take the time to read and accept the company policy by clicking the "I AGREE" button located at the bottom                                                                              

Effective date: 05/15/2024

TAG LENDING GROUP ANTI-MONEY LAUNDERING (AML) POLICIES & PROCEDURES MANUAL FOR TAGLENDING GROUP, LLC
(Mortgage Lender NMLS ID: 2329372)

335 S. Biscayne Blvd Ste #2809, Miami, FL 33131

860-462-7737– NMLS # 2329372

HR@taglendinggroup.com

 

PURPOSE

The purpose of this Anti-Money Laundering (AML) policy is to establish a framework for Tag Lending Group, LLC to detect, prevent, and report suspicious activities that may involve money laundering or other illegal financial activities. This policy ensures compliance with the Bank Secrecy Act (BSA) and the USA Patriot Act, reinforcing our commitment to maintaining a safe and compliant financial system.

SCOPE

This policy applies to all employees, agents, contractors, and affiliates of Tag Lending Group, LLC. It governs the detection and reporting of any suspicious activities, as well as requirements for record- keeping and customer identification.

POLICY STATEMENT


Tag Lending Group, LLC is dedicated to:

  • Preventing Money Laundering and Terrorist Financing: Implementing procedures to identify, report, and address money laundering and suspicious activities effectively.
  • Compliance with AML Regulations: Following all federal, state, and local laws, including the BSA, USA Patriot Act, and relevant Financial Crimes Enforcement Network (FinCEN) requirements.
  • Ongoing Training: Providing regular training for employees on AML compliance, reporting requirements, and the recognition of suspicious activities.

KEY COMPONENTS OF AML PROGRAM

1. Customer Identification Program (CIP)

Tag Lending Group, LLC requires verification of each customer's identity through the following means:

  • Collecting and verifying customer identification information, including full name, date of birth, address, and identification number.
  • Screening customers against relevant databases to ensure compliance with regulatory

2. Suspicious Activity Monitoring and Reporting 

   Employees are trained to recognize suspicious behaviors or activities, which may include large or irregular transactions, unusual requests, or complex structures that could indicate money laundering or fraud.

  •  Suspicious Activity Reports (SARs): Tag Lending Group, LLC will file SARs when transactions or behaviors raise concerns regarding money laundering, terrorism financing, or other suspicious activities. SARs must be filed with FinCEN within 30 days of identifying the suspicious activity.

3. Currency Transaction Reporting (CTR)

    All currency transactions of $10,000 or more are subject to Currency Transaction Reporting requirements. Tag Lending Group, LLC will complete and file a CTR with FinCEN for qualifying transactions to ensure compliance with the BSA.

4. Record-Keeping Requirements

  Accurate and detailed records are essential for AML compliance. Tag Lending Group, LLC will maintain all records related to:

  • SAR and CTR filings,
  • Customer identification and verification,
  • Internal audits and

  All records will be retained for at least five years in a secure and accessible manner, allowing for easy retrieval during an audit or regulatory review.

4. AML Risk Assessment

  The company will regularly conduct an AML risk assessment to evaluate vulnerabilities, identify higher- risk clients or transactions, and adjust procedures accordingly.

  • ROLES AND RESPONSIBILITIES  

    • Compliance Officer: Tag Lending Group, LLC has designated a Compliance Officer responsible for managing and enforcing this AML policy, overseeing SARs and CTR filings, and ensuring ongoing

    • Employees: All employees are responsible for understanding AML compliance requirements and immediately reporting any suspicious activities to the Compliance Officer.

  •   TRAINING AND AWARENESS

    Regular training will be conducted to ensure all employees understand their obligations under AML regulations. Training will include:

    •  Identification of suspicious activities

    • Reporting requirements for SARs and CTRs

    • Record-keeping responsibilities, and
    • Updates on relevant laws and regulations

     

POLICY REVIEWS AND UPDATES

This policy will be reviewed annually, or more frequently if needed, to ensure it reflects current regulatory requirements and industry best practices. Any updates will be communicated promptly to all employees.

 

ACKNOWLEDGEMENT

All employees of Tag Lending Group, LLC are required to review, understand, and acknowledge this policy annually. Non-compliance with AML policies and procedures may result in disciplinary action, up to and including termination of employment.

 

OWNER:

   
  Anthony Angelillo

TAG Lending Group, LLC

HR@TagLendingGroup.com

 

                      I  AGREE