Ive determined that I need a Red Flags Program, but since I already have an anti-money laundering program isnt that enough?
No. While a robust AML program makes it less likely that there will be an incidence of identity theft at your business, you still need a Red Flags Program that states how your company will detect and respond if an instance of identity theft or an attempt to use your credit facility to engage in identity theft were to occur. That being said, many of the steps you take for your AML program, such as getting ID from customers, will likely be the same steps you will include in your Red Flags Program.
