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
Not filing SARS every time one is required
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?<
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
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?
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™.