All of our lives changed on September 11, 2001. Things changed on that day not only for the American public, but also for the securities industry. As a result of the terrorist attacks on September 11, 2001, the US Congress passed the USA PATRIOT Act, which, among other things, mandated that financial institutions that were not formerly subject to the Bank Secrecy Act, implement an anti-money laundering program that is reasonably designed to achieve compliance with all applicable anti-money laundering rules and regulations. The NASD responded by creating and adopting NASD Rule 3011, which establishes the requirements for an anti-money laundering program for broker/dealers.
NASD Rule 3011 requires broker/dealers to create and implement an anti-money laundering (AML) program that, at a minimum, includes the following components:
• Establish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of suspicious activities or transactions.
• Establish and implement policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act.
• Provide for annual (on a calendar-year basis) independent testing for compliance to be conducted by member personnel or by a qualified outside party.
• Designate and identify to FINRA an individual or individuals responsible for implementing and monitoring the day-to-day operations and internal controls of the program.
• Provide ongoing training for appropriate personnel.
BDCA has experienced AML consultants that can help your firm comply with all applicable AML rules and regulations, including the establishment of Customer Identification Procedures, creation and submission of Suspicious Activity Reports, creation and implementation of policies and procedures, review of clients’ names against various federal lists, annual testing and AML training.
Please call us at (770) 263-6003 to find out how BDCA can help you with your AML needs.