AML Red Flags: The Clues to Combating Illegal Activity

Training Brokers and Operations is Critical for an Effective AML Program

The USA PATRIOT Act specifically requires your firm to establish a program to prevent money laundering and interdict possible terrorist financing activities.

Brokers who open new accounts are the first line of defense in protecting your firm. Their role is to follow firm procedures that may identify warning signs in customer accounts and escalate any suspicious activities to the attention of a supervisor or your firm’s compliance department.

The role of operations specialists or supervisors is to provide a second review of new accounts. You should continue to monitor the account process according to your firm’s policies and procedures manual, being especially mindful of the PATRIOT Act requirements.

This month’s newsletter, “Identification of Red Flag Activities,” provides specific lists of activities during the life of an account that are considered red flags and would require your firm to take action upon the discovery of these activities.

About the Course

AML Red Flags – Retail & Operations presumes that the reader has a basic understanding of the anti-money laundering requirements under the PATRIOT Act. The course details the role of a retail broker and an operations specialist in monitoring and evaluating firm risks in the operation of a broker/dealer. The course describes requirements for identifying and handling suspicious activities that may be linked to money laundering or other crimes.

In addition, the course briefly reviews a retail broker’s obligation to “know your customer,” as well as the important role of an operations specialist in the prevention of money laundering. The course focuses on red flags during three activity points during the life of an account: The opening, after opening, and transactions. Finally, a review of knowing how and when to report a suspicious activity is an essential part of keeping a firm in compliance with the PATRIOT Act.

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