- 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
- DVP Account
Delivery Versus Payment Account is a securities industry settlement procedure in which the buyer's payment for securities is due at the time of delivery. Delivery versus payment (DVP) is a settlement system that stipulates that cash payment must be made prior to or simultaneously with the delivery of the security. (source: http://www.investopedia.com/terms/d/dvp.asp)
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the United States Department of the Treasury that collects and analyzes information about financial transactions in order to combat money laundering, terrorist financiers, and other financial crimes. (source: Wikipedia - http://en.wikipedia.org/wiki/Financial_Crimes_Enforcement_Network)
- FinCEN 314(a) Requests
FinCEN receives requests from law enforcement and upon review, sends requests to designated contacts within financial institutions across the country once every 2 weeks via a secure Internet website.
The requests contain subject and business names, addresses, and as much identifying data as possible to assist the financial industry in searching their records. The financial institutions must query their records for data matches, including accounts maintained by the named subject during the preceding 12 months and transactions conducted within the last 6 months.
Financial institutions have 2 weeks from the transmission date of the request to respond to 314(a) requests. If the search does not uncover any matching of accounts or transactions, the financial institution is instructed not to reply to the 314(a) request.
The Financial Industry Regulatory Authority, Inc., or FINRA, is a private corporation that acts as a self-regulatory organization (SRO). FINRA is the successor to the National Association of Securities Dealers, Inc. (NASD). Though sometimes mistaken for a government agency, it is a non-governmental organization that performs financial regulation of member brokerage firms and exchange markets. The government organization which acts as the ultimate regulator of the securities industry, including FINRA, is the Securities and Exchange Commission. (source: Wikipedia - http://en.wikipedia.org/wiki/Financial_Industry_Regulatory_Authority)
The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.
OFAC acts under Presidential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under US jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments. (source: Treasury.gov - http://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Foreign-Assets-Control.aspx)
- Suspicious Activity Report (SAR)
A suspicious activity report (or SAR) is a report made by a financial institution and sent to the Financial Crimes Enforcement Network (FinCEN), an agency of the United States Department of the Treasury, regarding suspicious or potentially suspicious activity. Outside of the United States, SARs are known as STR (Suspicious Transaction Report).
- The Bank Secrecy Act (BSA)
The Bank Secrecy Act of 1970 (or BSA, or otherwise known as the Currency and Foreign Transactions Reporting Act) requires financial institutions in the United States to assist U.S. government agencies to detect and prevent money laundering.
Specifically, the act requires financial institutions to keep records of cash purchases of negotiable instruments, and file reports of cash purchases of these negotiable instruments of more than $10,000 (daily aggregate amount), and to report suspicious activity that might signify money laundering, tax evasion, or other criminal activities. (source: Wikipedia - http://en.wikipedia.org/wiki/Bank_Secrecy_Act)