Broker Dealer - Anti-Money Laundering Audits

AML Programs (Model or Customized)

SCA has developed a comprehensive program to help clients comply with their AML responsibilities. SCA’s program includes:

• A Customer Identification Program;
• A sample AML policy statement;
• AML E-Mail updating service;
• Staff time to assist in the customization process; and
• Written supervisory procedures including sample client forms and red flags to assist in monitoring activity and opening accounts.

AML Audits

FINRA AML Rule 3011 requires that member firms provide for an independent testing function to review and assess the adequacy and level of compliance with their AML compliance program. The rule allows for either internal testing by qualified personnel or the use of a qualified outside party. If firms choose to use internal personnel, they should maintain sufficient separation of functions 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. Firms 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.