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A Georgia licensee that meets the loan or finance company definition has no written anti-money laundering program in 2026. Does filing reports alone replace the required written anti-money-laundering program?

Correct Answer

A) Deficient: a written program is developed and implemented under the rule

Every person subject to Georgia licensing who meets the loan or finance company definition must develop and implement a written anti-money laundering program and comply with the filing, recordkeeping, currency transaction reporting and suspicious activity reporting requirements of the Bank Secrecy Act. Other choices: Georgia makes the federal obligation a state rule as well; filing reports is one element rather than the program; and no annual filing of the program with the Department is required. Source: Ga. Comp. R. & Regs. 80-11-1-.06(2)

Answer Options
A
Deficient: a written program is developed and implemented under the rule
B
Acceptable, because the Bank Secrecy Act is enforced federally and not here
C
Acceptable where the licensee files any suspicious activity reports it sees
D
Deficient: the program must also be filed with the Department each year

Why This Is the Correct Answer

Every person subject to Georgia licensing who meets the loan or finance company definition must develop and implement a written anti-money laundering program and comply with the filing, recordkeeping, currency transaction reporting and suspicious activity reporting requirements of the Bank Secrecy Act. Other choices: Georgia makes the federal obligation a state rule as well; filing reports is one element rather than the program; and no annual filing of the program with the Department is required. Source: Ga. Comp. R. & Regs. 80-11-1-.06(2)

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