- 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
- A rising number of firms are not maintaining adequate AML compliance programs and are subsequently facing sanctions by FINRA.
Although the SEC is the ultimate regulator of the securities industry, The Financial Industry Regulatory Authority, or FINRA, publishes Monthly Disciplinary Reports and is the private corporation that acts as a self-regulatory organization.
FINRA is a non-governmental organization that performs financial regulation of member brokerage firms and exchange markets.
- Evolving technologies have created opportunities for criminal enterprises, resulting in an increasing number of complex AML risks for exposed organizations.
Advances in technology and product innovation, along with expanding criminal enterprise, present an increased need for regulatory and risk mitigation considerations related to AML. An AML compliance program should consider risk exposure and contemplate mitigation steps for this changing landscape.
An example would be innovations in payment technologies. The use of international Automated Clearing House (ACH) transfers, remote deposit capture, and mobile phone payments present potential risks that require careful consideration.
- The economic environment for broker-dealers remains challenging, putting resource pressure on AML compliance programs.
Faced with increasing compliance costs, firms are seeking efficiencies in operations and technology to lower these rising expenses. The need to achieve efficiencies is driving firms toward centralization and standardization of AML operations, as well as function-level integration of AML and anti-fraud programs and resources. Such integration can drive improvements in program efficacy, real-time monitoring, and present the firm with other cost benefits.
- Ongoing regulatory changes require broker-dealer AML compliance programs to adjust quickly to internal and independent reviews.
The many regulatory changes coming from the three main bodies – FINRA, FinCEN, OFAC – require your ongoing attention. Your firm must continuously fine-tune systems, routinely train personnel and periodically refine risk assessments to manage an effective AML compliance program.
- Smaller institutions are faced with the same requirements but often neglect their obligations.
It is important to remember that money laundering and terrorist financing comes in all shapes and sizes. All financial institutions regardless of size and sector must comply with the regulations or face potential risk exposure, regulatory fines as well as criminal and civil liability.
- Broker-dealers must consider market manipulation, identity theft and other system intrusions as potential predicate financial crimes to AML compliance practice.
More and more, criminals are manipulating firms with low-priced securities, issues from particular countries and other creative ways to place and layer transactions for money laundering purposes. Keeping a watchful eye by setting trading alerts, money flows, customer account changes, and margin levels will advance AML and fraud compliance monitoring at the firm.