As Summer has turned to Fall and you are getting around to that “To Do” list that may have hit the back burner all summer, it’s time to focus on your year-end compliance priorities. Plenty of people use a pen and paper, calendar, or online diary without any issues. And yet, a new to do list seems to emerge daily with important items being left behind. Your “to do” list need not be complicated, though – schedule an independent Anti-Money Laundering (“AML”) compliance program inspection.
In compliance terms, a sound AML compliance program requires a company to develop and implement a written AML compliance program reasonably designed to achieve and monitor compliance with the requirements of the Bank Secrecy Act, and the implementing regulations promulgated thereunder by the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”).
Regulators have issued countless reminders with respect to obligations regarding suspicious activity monitoring and reporting obligations. In fact, the Financial Industry Regulatory Authority (“FINRA”) has listed AML as one its top exam priorities. Yet, year after year, enforcement cases are brought against broker-dealers for non-compliance. AML cases resulted in the most fines assessed by FINRA three years in a row.
Registered Investment Advisers that have voluntarily implemented an AML compliance program should have it inspected no less than annually by a qualified compliance consultant.
There is still time, though. Make the conscious decision to schedule an independent AML inspection test to remain in broker dealer compliance. This is a priority that deserves to be at the top of your list.
The AML Inspection test must focus on key aspects of your business, but, at a minimum, it must be designed to evaluate and test the following:
- Written policies and procedures
- Designation of a compliance officer responsible for AML
- AML screening and monitoring
- Risk management
- AML red flags
Plan and get your AML inspection test completed today by calling us at 631-801-2900.