Fuller Center for Housing - Anti-Money Laundering (AML) Policy Statement - Policy and Program Procedures

Sep 1, 2026

Fuller Center for Housing sets out mandatory anti-money laundering requirements for each covenant partner, including adoption of an AML policy, procedures, and internal controls. The program requires designation of an AML compliance officer, ongoing employee training, and an independent audit/testing function scaled to product and service risk. The document also defines how AML information must be handled when responding to FinCEN requests, including record searches, reporting timelines, and confidentiality protections.

LanguageEnglish

CategoryLetters

FormatDOCX

Pages10

Reading Time4 min

AccessFree to download

Compliance and Supervisory Procedures

Internal policies, procedures, and controls

Compliance officer designation and duties

Ongoing employee training

Independent audit function

AML Compliance Officer Designation and Duties

Sharing AML Information with Federal Law Enforcement Agencies

The Fuller Center for Housing - Anti-Money Laundering Policy Statement & Program Procedures Compliance and Supervisory Procedures for (Covenant Partner) (Street Address) (City, State ZIP Code) Fuller Center For Housing Anti-Money Laundering Program Overview All Fuller Center covenant partners are required to establish an Anti-Money Laundering Program (AML) that at a minimum will: 1. Develop internal policies, procedures, and controls In accordance with the Financial Crimes Enforcement Network (FinCEN)’s requirement that all nonbank mortgage lenders and originators implement an Anti-Money Laundering program effective compliance date August 13, 2012, all US Fuller Center covenant partner Boards of Directors are required to adopt a program policy, procedures and controls document. 2. Designate a compliance officer who will be responsible for ensuring that The Fuller Center’s AML Program is implemented effectively, including monitoring compliance by the company’s agents and brokers with their obligations under the program; The AML Program is updated, as necessary; and, Appropriate persons are educated and properly trained. 3. Offer ongoing employee training program The Fuller Center for Housing’s US Programs Department will provide its covenant partners ongoing training opportunities at the annual Covenant Partner Conference or through appropriate third party training services. 4. Establish Independent audit function to test for compliance Provide for independent testing to monitor and maintain an adequate AML program, including testing to determine compliance of the covenant partner’s Board of Directors and staff with their obligations under the Anti-Money Laundering Program. The scope and frequency of the testing must be commensurate with the risks posed by the Fuller Center for Housing covenant partner’s products and services. Such testing may be conducted by a third party or by any officer or employee of The Fuller Center covenant partner, other than the person designated as the designated compliance officer. This could be a staff person, board member or volunteer accounting or banking associate. For background information see: HYPERLINK "http://nationalmortgageprofessional.com/news29200/anti-money-laundering-debuts-non-banks" http://nationalmortgageprofessional.com/news29200/anti-money-laundering-debuts-non-banks and the Federal Registry with the Final Rule HYPERLINK "http://www.gpo.gov/fdsys/pkg/FR-2012-02-14/pdf/2012-3074.pdf" http://www.gpo.gov/fdsys/pkg/FR-2012-02-14/pdf/2012-3074.pdf I. (Covenant Partner) Anti-Money Laundering (AML) Policy Statement It is the policy of (Covenant Partner) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorists or criminal activity. Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages: Placement: Cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. Layering: Funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. Integration: Funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes. Because Fuller Center For Housing covenant partner organizations originate loans, mortgages and finance purchases on behalf of consumers, there is a very small but real risk of criminal activity through the purc

FAQs

What are the minimum requirements for a covenant partner’s AML Program?

Covenant partners must adopt AML policies, procedures, and controls, designate an AML compliance officer, provide ongoing employee training, and establish an independent audit/testing function to monitor compliance.

What is the role of the AML compliance officer (AMLCO)?

The AMLCO is responsible for ensuring the AML program is implemented effectively, including monitoring compliance by officers and employees, updating the program as necessary, and ensuring appropriate education and training.

How does the covenant partner respond to FinCEN requests for account or transaction information?

The covenant partner must immediately search records to determine whether relevant accounts or transactions exist, have the AMLCO respond to the request, report matches using FinCEN’s subject information form, and avoid replying when no match is found as allowed under Section 314(a) of the PATRIOT Act.

Sep 1, 2026

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