Compliance
AET maintains a comprehensive Bank Secrecy Act / Anti-Money Laundering compliance program designed to detect, prevent, and report suspicious activity per federal and state law.
Governance & Oversight
- →Documented risk assessment covering client types, asset classes, and transaction behaviors
- →Board-approved policies for AML/BSA, sanctions, customer identification, and recordkeeping
- →Annual independent reviews of the AML program and effectiveness
Core Program Components
The compliance framework incorporates requirements under the Bank Secrecy Act, USA PATRIOT Act, and FinCEN guidance, including:
Customer Identification (CIP / KYC)
Identity verification of account holders and authorized signers before establishing relationships.
Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
Risk profiling based on account type, asset type, jurisdiction, and expected transaction behavior.
OFAC & Sanctions Screening
Screening against U.S. Treasury Office of Foreign Assets Control lists and government watchlists.
Transaction Monitoring
Technology-assisted and manual surveillance to detect unusual or suspicious activity; potential filing of Suspicious Activity Reports (SAR).
Recordkeeping & Reporting
Maintenance of transaction records and compliance determinations; filing of Currency Transaction Reports (CTRs) and SARs with FinCEN.
Training & Awareness
All employees receive annual training on BSA/AML, OFAC obligations, red flags, fraud prevention, and escalation procedures.
Independent Review & Testing
Periodic independent audits and regulatory examinations verify control effectiveness.
Risk-Based Approach
Resources and monitoring intensity align with each relationship's risk profile.
Commitment to Clients
AET's compliance program ensures all transactions meet legal, ethical, and regulatory standards, while maintaining full cooperation with law enforcement and regulators and preserving client confidentiality.