Compliance & Anti-Money Laundering (AML)
American Estate & Trust (AET) maintains a comprehensive Bank Secrecy Act / Anti-Money Laundering (BSA/AML) compliance program designed to detect, prevent, and report suspicious activity in accordance with federal and state law.
Our compliance framework protects clients, counterparties, and the integrity of the financial system. It also ensures that AET meets its fiduciary obligations as a Nevada-regulated trust company operating under ongoing state supervision.
Governance & Oversight
Our program includes:
- A 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 its effectiveness
Core Program Components
Our compliance program incorporates all required elements under the Bank Secrecy Act, USA PATRIOT Act, and FinCEN guidance, including:
1. Customer Identification (CIP / KYC)
AET verifies the identity of all account holders and authorized signers before establishing a relationship.
Verification includes collection and validation of identifying information (such as name, date of birth, address, and government identification) and screening against sanctions lists.
2. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
Each client is assigned a risk profile based on factors including account type, asset type, jurisdiction, and expected transaction behavior. High-risk accounts receive additional documentation review and monitoring.
3. OFAC & Sanctions Screening
All customers, counterparties, and relevant transactions are screened against the U.S. Treasury Office of Foreign Assets Control (OFAC) lists and other relevant government watchlists.
Matches or potential matches are escalated immediately for review and disposition.
4. Transaction Monitoring
AET employs technology-assisted and manual surveillance to detect unusual, inconsistent, or suspicious activity. Patterns of concern — including layering, structuring, rapid fund movement, or unexplained third-party involvement — are escalated for investigation and may result in the filing of a Suspicious Activity Report (SAR).
5. Recordkeeping & Reporting
AET maintains records of transactions, identity documentation, and compliance determinations in accordance with federal retention requirements. Where required, AET files reports with the Financial Crimes Enforcement Network (FinCEN), including Currency Transaction Reports (CTRs) and SARs.
Training & Awareness
All employees with access to client information or transactional systems receive annual training covering:
- BSA/AML and OFAC obligations
- Red flags for suspicious activity
- Fraud prevention and phishing awareness
- Procedures for escalation and reporting
Training is documented and periodically updated to reflect evolving threats, new product offerings, and regulatory guidance.
Independent Review & Testing
AET’s AML program is subject to periodic independent audits and regulatory examinations, ensuring that our controls remain effective and responsive to changes in risk.
Independent testing includes:
- Review of CIP and onboarding documentation
- Evaluation of monitoring systems and alert handling
- Assessment of management reporting and escalation procedures
Findings are reported directly to the Board of Directors, with remediation tracked to completion.
Risk-Based Approach
AET applies a risk-based approach consistent with regulatory expectations. This means resources and monitoring intensity are aligned with the inherent risk profile of each relationship or asset type.
For example:
- Simple, low-risk retirement accounts are monitored differently from complex private-placement investments or multi-party real estate syndications.
- Certain instructions may require additional documentation (e.g., operating agreements, subscription agreements, or proof of authorization) before execution.
Cooperation with Law Enforcement & Regulators
AET fully cooperates with law enforcement, examiners, and other regulatory agencies as permitted or required by law. We provide information, reports, and documentation necessary to support investigations or regulatory inquiries while maintaining client confidentiality consistent with our obligations.
Continuous Improvement
We continuously refine monitoring logic, escalation criteria, and risk scoring to reflect:
- Updated regulatory guidance from FinCEN, OFAC, and the Nevada Financial Institutions Division (FID)
- Emerging risks related to new asset types, transaction channels, or geographies
- Lessons learned from audits, industry advisories, and real-world case studies
AET’s commitment to ongoing program enhancement ensures that we remain effective, current, and responsive to evolving financial-crime risks.
Commitment to Clients
Our program protects all parties by ensuring that every transaction and relationship meets legal, ethical, and regulatory standards. Clients benefit from a stable, compliant institution that places long-term trustworthiness above short-term convenience.