- 30 years of financial industry experience including AML compliance and training, securities firm operations and management
- 15 years of AML compliance advisory and education experience in the financial services industry
- Directed Securities Industry Institute at the Wharton School, University of Pennsylvania and other SIFMA training for member firms
- Faculty for Certified Compliance Regulatory Professional (CCRP) at Lubin School of Business, Pace University, ACAMS CAMS-Audit Certification, IMTC Compliance Certification Course, and ComplianceOnline
- Industry arbitrator for FINRA
- All 7 Best Practices
- Pre-Call Discovery Process
- One-on-One Call with Expert
- Session Summary Report
- Post-Session Engagement
Anti-Money Laundering - Broker-Dealers
Many securities broker-dealers, particularly small independent firms, think money laundering can't happen to them. They think that because they are smaller, they are less likely to come under regulatory scrutiny.
The Financial Industry Regulatory Authority (FINRA), which regulates broker-dealers, has demonstrated that in Anti-Money Laundering compliance, size does NOT matter.
Anti-Money Laundering compliance programs are required of brokers-dealers of all sizes under the Bank Secrecy Act and the USA PATRIOT Act, as prescribed by FINRA Rule 3310. Screening for OFAC sanctions is required by the U.S. Treasury.
In AML compliance, you are expected to have a reasonably-designed, effective AML compliance program tailored to the business of the firm. It must meet the "four pillars" requirements:
- Policies, procedures and internal controls
- Designated AML compliance officer
- Ongoing training for appropriate personnel
- Independent testing on an annual basis.
Ignoring your regulatory responsibilities will lead to enforcement actions and the potential of large fines. Senior managers, boards of directors and even compliance officers risk suspension, censure and fines. We've all read the FINRA enforcement actions.
The following Best Practices will help your firm, regardless of size, avoid the penalties, reputational harm and business damage that result from failure to comply with AML regulations.