S.D. Daniels & Company, LLC (SDDco-LLC) provides independent testing of the Anti-Money Laundering (AML) programs of FINRA member broker-dealers and other financial institutions. Our testing professionals are Certified AML Specialists (CAMS) and members of the Association of Certified Anti-Money Laundering Specialists (ACAMS).
SDDco-LLC conducts an independent, in-depth review to test conformity with applicable AML mandates of the Bank Secrecy Act (BSA), USA Patriot Act of 2001, and governmental administrators, such as the Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), and of the self-regulatory organization, the Financial Industry Regulatory Authority (FINRA).
Such AML rules will vary in their application depending on the structure and function of each broker-dealer. Consistent with BSA and other AML regulations, FINRA Rule 3310 and its amendments instruct member firms to observe AML standards. The BSA applies to all broker-dealers; there are no exceptions. SDDco-LLC also offers AML testing for investment advisors, although not currently required by the SEC.
SDDco-LLC determines 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. An AML tester must know the requirements of the Bank Secrecy Act and its regulations. However, the AML test may not be conducted by any person who performs the functions being tested, such as the designated AML compliance person, a member of your AML compliance team, or by any individual who reports to either.
The scope of the AML test performed is tailored to emphasize the aspects of AML requirements most relevant to the business operations of your firm. In this manner, SDDco-LLC tests the firm’s AML Compliance Program and the business practices that pose the highest degree of risk. SDDco-LLC’s AML testing includes review and analysis of business operations, review and analysis of AML supervision and management, and review and analysis of records.
Upon completion of the testing process, SDDco-LLC will provide a written report on findings and recommendations, details of the manner and method of your firm’s internal AML compliance testing, a report on firm compliance with your AML supervisory system and AML WSP, a summary of the gaps discovered, and identification of the changes your firm has made or will need to make to enhance the effectiveness of your AML compliance program.
SDDco-LLC is here to address any deficiencies discovered through the AML testing. Please contact us if you have further questions about our AML testing services.