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Anti-Money Laundering

In 2016, AML was at the top of FINRA’s enforcement list for the first time – and shows no sign of abating. While there was an 11% decrease in the number of cases reported, there was a whopping 123% increase in fines – with almost 30 cases involving fines, sanctions, or suspensions of a Compliance officer.

Reasons for Current FINRA Enforcement Actions

Common FINRA enforcement actions for this year are related to:

  • Not targeting all firm and business-specific risks
  • Inadequate resources devoted to AML and an overreliance on account openers to conduct due diligence
  • Failing to perform annual testing of AML policies, procedures, program, and training
  • Flawed technology, inadequate systems, data integrity issues and lack of effective oversight
  • Not filing SARS every time one is required

Firm Self-Check

  • Do you have an AML program that satisfies your firm’s compliance obligations?
  • Do your employees have a cogent understanding of all facets of anti-money laundering and what their specific role is?< /li>
  • Does your training program provide role and transaction-specific case studies and scenarios?
  • Do your employees actively engage in fully knowing their client and the transactions in which they are involved, and in understanding their particular areas of risk?
  • Does your Compliance program properly and proactively identify new risks that come with new business?
  • Do you have adequate communications between business units, AML and KYC groups, and Compliance?
  • Do you train your independent contractors on AML?
  • Do you perform an annual review of your AML policies, procedures, and training?

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If you answered “Not Sure” or “No” to any of these questions, give us a call today!

Let the experts at i3 support improvements to your AML and KYC staffing, policies, procedures, training, and awareness.

Establish a “See something, Say something!” mentality across your organization!

Contact Us Today to schedule your Initial Information Integration Evaluation™.