New ways to launder money and engage in fraudulent activities have put broker dealers under increased pressure to remain compliant. The USA Patriot Act and FINRA Rule 3310, require broker dealers and dually-registered firms to design and implement an AML program that includes appropriate policies and procedures, a customer identification program, and an annual review of the firm’s policies and procedures.
NRS audits a firm’s AML program to determine if it is compliant with FINRA rules and the USA Patriot Act. Working with key stakeholders at your firm, NRS expert compliance professionals conduct an onsite review and test of your firm’s AML program and related policies and procedures. NRS delivers a report addressing firm’s program soundness. This allows broker dealers and dually-registered firms to meet annual requirements as outlined by FINRA for an independent AML program review.
NRS expert compliance professionals:
- Review and test the AML written supervisory policies and procedures
- Review client files with an emphasis on foreign clients
- Review and test internal surveillance practices
- Review the AML training plan for all appropriate personnel
- Review for required AML documentation
- Deliver a written report highlighting deficiencies and recommending appropriate corrective measures