What should an AML compliance program look like for a foreign-owned LLC that is classified as an MSB?
My foreign-owned LLC provides currency exchange services for tourists and has been classified as a Money Services Business. FinCEN says I need a written AML compliance program. I am a small operation — just me and two employees. What are the minimum requirements for an AML program? Do I need to hire a compliance officer? How much should I expect to spend on this? Can I write the program myself or do I need a lawyer?
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