AML Audits

NASD AML Rule 3011 requires that member firms provide for an independent testing function to review and assess the adequacy of and level of compliance with the firm’s AML compliance program. “The rule will allow for either internal testing by qualified personnel or the use of a qualified outside party. If a firm uses internal personnel, sufficient separation of functions should be maintained to ensure the independence of the internal testing personnel. The independent testing should be performed annually. After a test is complete, the auditor should report findings to senior management or to an internal audit committee, as appropriate. The firm must ensure that there are procedures for implementation of the auditor’s recommendations and corrective or disciplinary action as the case may warrant.

If your firm does not have a sufficient number of qualified internal personnel to maintain separation of functions so that the individual(s) testing the AML program are not involved in monitoring day-to-day AML compliance, you may need to hire an outside firm to conduct your annual audit. If you feel you have adequate personnel it may be more cost effective to conduct the testing internally.

Either way, SCA can provide assistance. You may purchase our internal audit program and customize it to fit your firm’s needs or SCA will conduct the audit utilizing our qualified audit personnel. SCA also offers audit training to a client’s internal audit staff.