Anti-Money Laundering Policy

OPEN ARMS HEALTHCARE LLC

POLICIES AND PROCEDURES

Anti-Money Laundering (AML) Policy

Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to ensure that Open Arms Healthcare, LLC complies with all applicable federal and state laws designed to prevent money laundering, fraud, and financial crimes.

This policy establishes guidelines to detect, prevent, and report suspicious financial activity related to healthcare services and operations.

Scope

This policy applies to all employees, contractors, and administrative staff.

It includes billing, payroll, financial operations, and client service documentation.

Policy Statement

Open Arms Healthcare, LLC is committed to preventing the use of its services for money laundering or fraudulent activity.

The organization will maintain accurate financial and service records and comply with all regulatory requirements.

Definition of Money Laundering

Money laundering is the process of concealing the origin of illegally obtained funds by passing them through legitimate businesses or financial systems.

Risk Areas

Billing for services not rendered

Duplicate or inflated claims

False timesheets or EVV discrepancies

Payments from unknown or third-party sources

Unusual billing patterns

Responsibilities

Administration: Oversee AML compliance and investigate suspicious activity.

Billing Team: Verify claims and monitor transactions.

Care Staff: Accurately document services and report inconsistencies.

Monitoring and Reporting

Employees must report any suspicious activity immediately to administration.

The company may report to appropriate authorities if necessary.

Recordkeeping

All financial and service records will be maintained for 5–7 years.

Records must be accurate, complete, and secure.

Training

All staff will receive AML training during onboarding and annually thereafter.

Internal Controls

Separation of duties

Regular audits

Approval processes for billing

Monitoring payroll and reimbursement patterns

Non-Compliance

Failure to comply may result in disciplinary action, termination, or legal consequences.