AML and Suitability

AML and Suitability Challenges During COVID-19

FINRA Rule 3310 provides broker-dealer guidance on how to design, test, and enforce a firm’s Anti-Money Laundering Program (“AML”). One main element of AML is to “establish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of transactions required under 31 U.S.C. 5318(g) and the implementing regulations thereunder.” FINRA Notice to Members 19-10 identified a key list of red flags that may be used to help identify suspicious activity in trading, money movements, insurance, and securities.

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Compliance

Compliance and COVID-19: Opportunities for Growth

The spread of the COVID-19 pandemic has presented challenges for many financial service firms. Compliance programs are no exception. Firms are generally responsible for building, testing, and enforcing their compliance programs.

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Teleworking

Teleworking Considerations During COVID-19 Pandemic

Many financial service institutions have been hesitant to create teleworking processes and systems that would give them more flexibility to service clients and build the business. However, within the regulatory framework, landmines appear at every turn.

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BCP

BCP and COVID-19: Considerations for Firms

Many financial service firms have written supervisory procedures in place for business continuity planning (BCP). Tucked somewhere on a server or in a binder, many plans have been collecting dust. More than likely, these plans are only taken out during regulatory exams, branch audits, or internal testing.

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