Achieve peace of mind with anti-money laundering compliance.

Finally, a no-nonsense way for mortgage brokers and lenders to confidently manage anti-money laundering (AML) compliance for audit requirements.

  • Upfront pricing

  • Quick turnaround

  • Experienced reviewer

Anti-money laundering compliance

will come up in your next audit.

Do you know what the auditor will require? Let me tell you.

Red Flags

Unmasking Suspicious Activity: Real-Life Examples and Red Flags

September 02, 20231 min read

What do I mean by “suspicious activity?”

Here are 8 real-life examples and red flags:

1. False documentation

Providing fraudulent or falsified documents, such as income statements, tax returns, employment verification, or bank statements, to misrepresent financial eligibility.

2. Identity theft

Using stolen identities or creating fake identities to secure a mortgage loan.

3. Straw buyers/sellers

Involving a third party who poses as the buyer to obtain a mortgage loan on behalf of someone else, often for illegal purposes. Involving fictitious sellers or individuals with no ownership interest in the property to deceive lenders regarding the property's value.

4. Property flipping schemes

Engaging in rapid property purchases and sales at inflated prices to deceive lenders and profit from the artificially inflated appraisals.

5. Undisclosed debt

Failing to disclose existing loans, debts, or financial obligations to lenders, creating a misleading financial profile.

6. Collusion

Collaborating with appraisers, mortgage brokers, or real estate agents to manipulate property values, loan terms, or other aspects of the mortgage origination process for personal gain.

7. Cash-back schemes

Providing inflated purchase prices, resulting in excess loan proceeds that are then returned to the borrower or other parties involved.

8. Missing or altered information

Deliberately omitting or modifying crucial details on mortgage applications or related documents.

If you’re not sure, reach out and we can talk through it.

Back to Blog

What is an AML independent review?

An AML independent review is a third-party verification of your company's compliance with anti-money laundering (AML) regulations.

It is required annually by federal regulations and auditors will ask you for it.

Failure to comply can result in civil and criminal penalties ranging from:

  • fines up to $1,677,030

  • forfeiting assets

  • imprisonment up to ten years

Want to Stay Informed?

What is an AML independent review?

An AML independent review is a third-party verification of your company's compliance with anti-money laundering (AML) regulations.

It is required annually by federal regulations and auditors will ask you for it.

Failure to comply can result in civil and criminal penalties ranging from:

  • fines up to $1,677,300

  • forfeiting assets

  • imprisonment up to ten years

Relax.
We’ll make it simple.

Our AML Independent Review

guarantees you are compliant in time for your audit

+

empowers you to continue managing your compliance

What's the review process?

Meet with a Certified
Anti-Money Laundering Specialist.

They will thoroughly explain every requirement and make recommendations for your company in an efficient one-hour conference call.

Provide the required documents for the AML compliance review.

Don’t worry—your Certified Anti-Money Laundering Specialist will tell you what documents are needed and how you can prepare them.

Receive a formal report to provide to auditors in time for your audit.

Well that was easy—and totally worth every penny! And now you know everything you need to keep your AML program running smoothly.

Come away with confidence.

We'll teach you what you need.

AML Risk Assessment

State auditors will ask you for an AML Risk Assessment completed within the last 12–18 months. Our AML Independent Review allows you to carefully assess your company’s money laundering risk as regulation demands—your products, your customer base, and your subject property geography.

AML Program Adoption

Your company’s AML progam must be reviewed and approved annually by the Board or Senior Management. Our AML Independent Review includes a program adoption tool that will help you understand what it takes to successfully run your AML program. Whether it’s about designating the right officer, managing compliance requirements, and overseeing yearly reviews to mitigate risks and unpredictable outcomes, this resource is designed to inform you what to do and how.

AML Officer Designation

You must designate an officer for your AML program, approved by the Board or Senior Management. An AML officer oversees your company’s AML program and ensures requirements are met. Our AML Independent Review will tell you everything that’s expected of the AML officer and facilitate designation and approval.

Mortgage Broker's Guide to Red Flags

You may not have realized it, but money laundering is a daily risk in mortgage origination. It is critical for mortgage brokers to identify higher-risk customers, potential money laundering and fraud, and prevent your company from being involved in money laundering schemes. Our AML Independent Review provides case studies of mortgage money laundering methods, popular ways to launder money, and money laundering red flags.

Don't wait 'til it's too late.

Get an independent review to guarantee your AML audit success and worry less about your compliance.

Meet Jo Brown.

Certified Anti-Money Laundering Specialist

Anyone else feel like Chunk in The Goonies movie when introducing themselves? “Okay! I’ll talk! In third grade, I cheated on my history exam. In fourth grade, I…”


Of course, I didn't cheat! I am passionate about compliance—specifically mortgage compliance and anti-money laundering. I actually enjoy compliance! Weird, huh?!


I’ve been audited in some capacity for the majority of the last 20 years.

Through this experience I've learned that audits are not something to be dreaded. In fact, they are a great opportunity for growth. I pride myself on getting exemplary results while maintaining a smile on my face.

I started out as a part-time teller in college while getting a Bachelor of Science in Psychology. Banking stuck and I spent seven years in retail branch banking. 

  • Monthly branch audits

I spent the next seven years as Vice President, Bank Secrecy Act Officer and Deposit Compliance Officer for a regional bank. 

  • State audits

  • Federal Reserve Bank exams

I have been Chief Compliance Officer of a regional mortgage lender for three years.

  • Warehouse line audits

  • FHA audits

  • VA audits

  • Post-close QC audits

  • State audits

I have been a Mortgage Compliance Consultant for one year. 

  • Mortgage broker nationwide state audits

Frequently Asked Questions

What is your turnaround time?

24 hours from the time all documents have been submitted.

How do I schedule the review?

Click the "Start a review" button to purchase and schedule.

Can I schedule before I purchase it?

No, however you’re welcome to submit questions prior to purchase.

Do you offer a membership or monthly payments?

No.

What if I get a review and still fail the audit?

Get your money back if you get a finding/violation specific to your AML independent review. However, success on other portions of your audit outside of AML compliance cannot be guaranteed as the review you purchase only covers AML.

What if the first meeting goes over an hour because I have so many questions?

That’s totally fine and there’s no additional cost.

What if I still have questions about managing AML compliance after my review?

Feel free to ask questions any time regarding AML compliance.

What are all the consequences of failing to comply with federal AML regulations?

Civil monetary penalties

For a detailed list of code U.S. code citations, penalty descriptions, and maximum penalty amounts, check out this document from the Financial Crimes Enforcement Network (FinCEN).

Forfeiture of assets

Any currency or other monetary instruments which are in the process of any transportation with respect to which a report is required under § 1010.340 are subject to seizure and forfeiture to the United States if such report has not been filed as required in § 1010.360, or contains material omissions or misstatements. The Secretary may, in his sole discretion, remit or mitigate any such forfeiture in whole or in part upon such terms and conditions as he deems reasonable.

Criminal penalties

(a) Any person who willfully violates any provision of Title I of Public Law 91-508, or of this chapter

authorized thereby may, upon conviction thereof, be fined not more than $1,000 or be imprisoned

not more than 1 year, or both. Such person may in addition, if the violation is of any provision

authorized by Title I of Public Law 91-508 and if the violation is committed in furtherance of the

commission of any violation of Federal law punishable by imprisonment for more than 1 year, be fined not more than $10,000 or be imprisoned not more than 5 years, or both.

(b) Any person who willfully violates any provision of Title II of Public Law 91-508, or of this chapter

authorized thereby, may, upon conviction thereof, be fined not more than $250,000 or be imprisoned

not more than 5 years, or both.

(c) Any person who willfully violates any provision of Title II of Public Law 91-508, or of this chapter

authorized thereby, where the violation is either

• Committed while violating another law of the United States, or

• Committed as part of a pattern of any illegal activity involving more than $100,000 in any 12-month period, may, upon conviction thereof, be fined not more than $500,000 or be imprisoned not more than 10 years, or both.

(d) Any person who knowingly makes any false, fictitious or fraudulent statement or representation in any report required by this chapter may, upon conviction thereof, be fined not more than $10,000 or be imprisoned not more than 5 years, or both.

Are you really the only company that offers AML independent reviews?

No, but good luck finding a company that caters to the mortgage industry and is as quick as we are!

Do you offer any consulting services?

No.

Any other questions?

Any other questions?

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