Category: Anti-Money Laundering

It has been an exciting year for Securities Compliance Management (“SCM”)

The Ultimate Solution for Compliance Management

Posted on by SCM Communications

It has been an exciting year for Securities Compliance Management (“SCM”). The Firm has successfully: Initiated numerous New Membership Applications (“NMAs”) for new firms seeking the Financial Industry Regulatory Authority’s (“FINRA”) approval, Initiated several Continuous Membership Applications (“CMAs”) for existing firms that are planning to undergo a material change in their line of business operations, Partnered with new broker-dealer and registered investment advisor firms to assist them with their FinOp and/or compliance programs, and Assisted in the buy/sell of existing broker-dealer firms. Along with the new relationships that Securities Compliance Management has established this year, the Firm is also incredibly Read more about The Ultimate Solution for Compliance Management[…]

FINRA Unscripted Podcast: AML Update

FINRA Unscripted Podcast: AML Update

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FINRA recently released a podcast AML Update: The Latest Trends and Effective Practices . This podcast provides a great update on the current AML and fraud trends and best practices from Jason Foye, Senior Director of the National Cause and Finance Crimes Detection Program’s Special Investigative Unit . A few highlights from the AML update podcast: Financial Crimes Enforcement Network (FinCEN) Priorities On June 30, 2021, FinCEN posted a bulletin that set out eight priorities, focused on threats to the U.S. financial system and national security. These priorities include corruption, cybercrime (including relevant cybersecurity and virtual currency considerations), foreign and Read more about FINRA Unscripted Podcast: AML Update[…]

Considerations for FinCEN 314(a) Policies and Procedures

Considerations for FinCEN 314(a) Policies and Procedures

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The Financial Crimes Enforcement Network (FinCEN) is a program under Rule 31 CFR Part 1010.520 that requires certain financial institutions to search their records and identify if they have responsive information with respect to the particular investigative subject. This provides a service to law enforcement by providing an additional layer to help locate financial assets and recent transactions of individuals, entities, and organizations engaged in or reasonably suspected, based on credible evidence, of engaging in terrorist acts or money laundering activities. Who is required to perform FinCEN reviews? Currently, only broker-dealers are subject to FinCEN program 314(a) requirements. Registered investment Read more about Considerations for FinCEN 314(a) Policies and Procedures[…]

Filing A Suspicious Activity Report ("SAR")

Filing A Suspicious Activity Report (“SAR”)

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The Financial Crimes Enforcement Network requires certain financial institutions to file a Suspicious Activities Reports (“SAR”) to report suspicious transactions, as detailed in their FinCEN SAR Electronic Filing Instructions. This blog will go over some of the important aspects of filing a Suspicious Activity Report.

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AML and Branch Audits

AML and Branch Audits in the Time of COVID-19

Posted on by SCM Communications

At the beginning of the year, FINRA released important updates related to supervision requirements for broker-dealers. As broker-dealers and their employees started experiencing various work-from-home, virtual meeting, and operations challenges, FINRA provided valuable guidance for the transition in a FAQ related to the coronavirus pandemic. Below are a few items where FINRA has provided areas of relief related to AML and Branch audits. AML Independent Testing FINRA Rule 3310, Anti-Money Laundering (“AML”) Compliance Program, requires firms to perform independent testing of their AML program every calendar year. If a member firm neither executes transactions for customers, holds customer accounts, nor Read more about AML and Branch Audits in the Time of COVID-19[…]