Quisqueyana's Anti-Money Laundering Compliance Program is a multi-layered system of data processing, information gathering, communication, and reporting, which reflects our commitment to compliance with all federal and state requirements. Regulators and independent examiners recognize our sophisticated AML Compliance Systems as second to none in any tier of the financial services industry.
The key elements of the program include:
Know Your Customer Procedures (these apply to customers, agents, correspondents and employees)
Transaction Monitoring. Filtering of all transactions from any source to identify relational characteristics by name, telephone number and address that suggest possible structuring. RQI employs a ýCase Managementţ program to document the investigation and resolution of transactions that are reviewed for possible suspicious activity.
Agent and Employee Training Program. Communication of key aspects of State and Federal Regulations, including Bank Secrecy Act Title 31, and USA Patriot Act, as well as RQI AML Compliance policies and procedures. Annual on-site training of all employees and agents.
OFAC Program. RQI's processing system, Qe, compares all transactions against OFAC's list of Specially Designated Nationals (SDN) List, by downloading the list from OFAC once a week, and whenever it is updated.
Agent Risk Segmentation and monitoring of agent transaction averages and spikes in volume
Real Time Interface with External Compliance Officer Inc. (ECO) System, an external, redundant database of transactions processed through other money transfer companies, which allows us to broaden our search for suspicious patterns.
Protection of Privacy of Information: Gramm-Leach-Bliley Act.
Quisqueyana adheres to a policy of "Zero Tolerance" for any act of non-compliance or circumvention of procedures and regulations. The policy is reinforced through continuous training and communication with all employees, agents and correspondents.
The USA Patriot Act requires four major procedural compliance components from a money transmitter. These are:
A designated Compliance Officer
A Written Compliance Manual. RQI has had one since 1999.
An Ongoing Training Program
Periodic External Audits/Independent Testing
RQI is in compliance with all four requirements. RQI has had a Compliance Officer since 1994. Today the post is filled by Juan Llanos, a Certified Anti-Money Laundering Specialist. RQI employs the audit services of Michael McDonald, a leading specialist in anti-money laundering systems and a former IRS investigator. Quisqueyana's Compliance Committee, comprised of the CEO, the VP of Compliance, the VP of Credit, the VP of Money Transfers, the Human Resources Manager and the Agent Franchise Manager, meets quarterly to review and update compliance policies, procedures, system functionalities and other issues. In addition, the CEO and VP of Compliance have both scheduled monthly meetings and ad hoc meetings, as necessary.
The quality of RQI's AML systems has been proven and attested to time and again by third parties. Quisqueyana's CEO, its VP of Compliance and its Executive Vice President are frequent speakers at a variety of industry-related conferences such as the American Bankers Association, the Money Transmitters Regulators Association, and the Inter-American Development Bank.
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