Broker/dealers are required to comply with the USA Patriot Act and FINRA rules. FINRA Rule 3310 generally requires member firms to provide for annual (on a calendar-year basis) independent testing of their AML Compliance Programs.
Anti Money Laundering (AML) Independent Testing
S.D. Daniels & Company, LLC (SDDco-LLC) provides independent testing of the Anti Money Laundering compliance programs of broker/dealers to assist you to meet this requirement. We conduct an independent, in-depth review to test conformity with all applicable AML mandates including the requirements of Financial Industry Regulatory Authority (FINRA), Bank Secrecy Act (BSA), USA Patriot Act of 2001, Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).
SDDco-LLC will determine if your firm maintains and implements AML Policies and Procedures that address applicable regulatory requirements, have been updated to incorporate new and amended rules and regulations; have been properly authorized by senior management; and have been distributed to and acknowledged by all associated persons.
Scope of Testing
SDDco-LLC will conduct an analysis of your firm’s business operations to determine the scope of the Independent Test to be performed. SDDco-LLC will analyze these aspects of your business: Products & Services; Branch Office(s); Client Base, Clearing Method(s); Possession and Control of Funds & Securities; Receipt and Forwarding of Funds & Securities; Transaction Volume; Account Activity; and Ownership Structure.
AML Testing Report
Upon completion of the testing process, SDDco-LLC will provide an AML testing report on their findings and recommendations. SDDco-LLC will detail the manner and method of your firm’s internal AML compliance testing. In addition, SDDco-LLC will report on the quality of your firm’s AML Supervisory System and AML Written Supervisory Procedures. SDDco-LLC will provide a summary of the gaps discovered and identify the changes your firm has made or will need to make to enhance the effectiveness of your AML Compliance Program.
CAMS Certified AML Professionals
SDDco-LLC AML professionals are certified members (CAMS) of ACAMS—The Association of Certified Anti-Money Laundering Specialists.
What is Anti-Money Laundering?
Anti-money laundering (AML) is the term used in the finance field and legal community to explain the constraints required of financial institutions and other regulated businesses to block, identify and report money laundering, which is the act of disguising the origin of money obtained by unlawful methods.