FINRA Updates Anti-Money Laundering Template for Small Firms

Per the Bank Secrecy Act (BSA) and FINRA Rule 3310, FINRA member firms are required to establish Anti-Money Laundering (AML) compliance programs. To assist its smaller member firms with fulfilling these responsibilities, FINRA publishes the “Anti-Money Laundering Template for Small Firms”, which provides instructions, relevant rules, text examples, relevant websites, and other resources that can be used to develop an AML plan for a small firm.

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New Anti-Money Laundering Program Requirements

Recently, the Financial Crimes Enforcement Network (“FinCEN”) adopted a final rule on Customer Due Diligence (“CDD”) Requirements for Financial Institutions.   As a result, firms will be required to address the new requirements within their Anti-Money Laundering (AML) programs.  Firms must be in compliance with its provisions by May 11, 2018.

Initially, firms’ AML programs were required to meet, at a minimum, the statutorily enumerated “four pillars” that were established by the Bank Secrecy Act (BSA).  The four pillars included the following: Read More…

AML Requirements for Investment Advisers

The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has proposed rulemaking that would require registered investment advisers to establish anti-money laundering (“AML”) programs and to file suspicious activity reports (“SARs”). The new requirements, as proposed, may impose significant regulatory burden on certain investment advisers. In this blog post, we provide a summary of the proposal to help your firm assess the potential impact, if any, the new requirements would have on your firm’s business. We conclude by providing, as a reminder, a list of the limited AML requirements that currently apply to investment advisers. Read More…

Anti-Money Laundering Compliance: The Basics

About a month ago, FINRA announced that it would be fining Raymond James & Associates and Raymond James Financial Services for $17 million for widespread failures in Anti-Money Laundering (AML) compliance. The former AML Compliance Officer at Raymond James & Associates, Linda Busby, was suspended three months and fined for $25,000 herself. No one at Raymond James, Ms. Busby or otherwise, was participating in the intense, dramatic money-laundering schemes seen in fiction; instead, the firms simply grew much more quickly than their compliance systems did, resulting in many possible incidents of suspicious activity going undetected or uninvestigated. As Raymond James’ recent fine shows, it is very important to keep up-to-date with AML Compliance. Read More…