I have a client that has several million dollars of sales each year and uses PayPal for some of those sales. He received a notice that his PayPal account has been frozen because his accountant has to provide an audit of their "Anti- Money Laundering Program." He also sent the following:
SEC. 352. ANTI-MONEY LAUNDERING PROGRAMS. (a) In General.--Section 5318(h) of title 31, United States Code, is amended to read as follows: ``(h) Anti-money Laundering Programs.-- ``(1) In general.--In order to guard against money laundering through financial institutions, each financial institution shall establish anti-money laundering programs, including, at a minimum-- ``(A) the development of internal policies, procedures, and controls; ``(B) the designation of a compliance officer; ``(C) an ongoing employee training program; and ``
(D) an independent audit function to test programs.
Has anyone performed this audit function service for a client and, if so, where can I go to get more information on it?