- 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-Meeting Discovery Process
- One-on-One Call with Expert
- Meeting Summary Report
- Post-Meeting Engagement
Anti-Money Laundering - Broker-Dealers
- Broker-dealer firms are facing a more complex regulatory environment while facing increased resource constraints.
While large broker-dealer firms utilize vast technology solutions and myriad resources to manage programs, smaller firms face the same vulnerabilities, risks, and regulatory expectations. Yet the smaller firms have smaller budgets and fewer resources and are often working with manual systems to manage these complex programs.
- Smaller broker-dealer firms may be misled into thinking that compliance and money laundering concerns are less likely to affect them.
Many firms, particularly smaller institutions, often think they don't need complicated programs and requisite resources. They also believe, falsely, that because of their relative smaller size they are less likely to come under regulatory scrutiny. Regulatory lapses come with significant consequences for broker-dealers of all sizes. Senior managers, boards of directors, and even compliance officers risk suspension, censure, fines and more.
- An effective AML compliance program can quickly degrade if the firm does not stay on top of and communicate to internal personnel all major regulatory changes.
No AML program can remain static. It's not enough to establish an AML compliance program and hire a qualified compliance officer to manage it. Maintain ongoing attention to all regulatory changes, including beneficial ownership, international third-party payments, and the modification of rules whether from FINRA, FinCEN or OFAC.
- Broker-dealers fail to adequately understand and analyze risk.
Understanding risks inherent to a broker-dealer firm and its market is critical to AML compliance. AML risk assessment is essential and must be dynamic enough to keep up with the firm's market and relevant AML regulations. It is a regulatory expectation that an AML compliance program be modified and updated to reflect regulatory updates and changes in the business of the firm.
- Business decisions are made without input from the AML compliance officer, resulting in insufficient AML controls on new products.
The compliance officer must have a seat at the table when a firm is considering expansion, whether in number of locations or of products and services. Compliance would be ineffective should a new product or service be rolled out with reviewing potential AML risks and mitigating controls.
- Broker-dealers fail to address or document findings and recommendations detailed in regulatory exams and independent reviews.
Firms must adequately address outcomes of reviews resulting from regulatory (SEC, FINRA, State) examinations and independent tests. The purpose of the independent review is to identify weak controls and deficiencies, and the firm is expected to address findings or implement any recommended changes, or state why they are not implementing recommendations. Firms are expected to track all corrective actions until they are resolved. Regulatory examiners may take a negative view of the firm who does not take seriously findings and recommendations, and may see this as a systemic problem.