Anti-Money Laundering Regulations: Key Focus Areas

The world of money laundering is fast-paced and ever evolving, which can make it difficult for a financial firm to develop and maintain a strong anti-money laundering program.

A broker-dealer firm’s anti-money laundering efforts may overlap with any number of other regulatory concerns. Firm regulatory risks and priorities don't exist in a vacuum. And that is perhaps nowhere clearer than when it comes to a firm's anti-money laundering responsibilities. A firm's AML risks can overlap with any number of other priorities.

On this episode, the first of a two-part series, we look at the overlapping risks of AML and cybersecurity.

Compliance with the Bank Secrecy Act

Firms must comply with the Bank Secrecy Act and its implementing regulations ("AML rules"). The purpose of the AML rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation. In the securities world today, there is little daylight between money laundering and fraud.

FINRA Rule 3310: Minimum Standards for AML Compliance Programs

FINRA reviews a firm’s compliance with AML rules under FINRA Rule 3310, which sets forth minimum standards for a firm’s written AML compliance program.

Customer Identification Rule and SEC's Books and Records Customer Account Records Rule

Two important regulatory developments relate to obtaining customer information: the Anti-Money Laundering Customer Identification Rule and the SEC's Books and Records Customer Account Records Rule. These rules require that important customer identification be obtained. However, these rules have critical differences including their purposes, their definitions, and their timing requirements.

We created this document to assist our member firms. It contains brief summaries of the rules' relevant provisions.

FINRA's Examination Process for AML Procedures

This webcast focuses on what firms should expect from the Anti-Money Laundering reviews conducted as part of FINRA's routine examinations. We will review how FINRA examiners will check to make sure you have appropriate AML procedures in place, and you will learn what we expect of you and what you should expect from us during the AML part of an exam.

Russia-related Sanctions Developments

The Special Investigations Unit (SIU) within FINRA’s National Cause and Financial Crimes Detection (NCFC) program is bringing to your attention some additional Russia-related sanctions developments. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) orders under new authority to counter illicit opioid trafficking.

Tools and Resources

FINRA provides a template for small firms (Word format 164 KB) to assist them in fulfilling their responsibilities to establish the Anti-Money Laundering Program.

Each course presents unique scenarios that illustrate typical money-laundering situations.

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