Anti-Money Laundering (AML) Template for Small Firms

FINRA provides a template for small firms (Word format 164 KB) to assist them in fulfilling their responsibilities to establish the AML compliance program required by the Bank Secrecy Act and its implementing regulations and FINRA Rule 3310. The template provides text examples, instructions, relevant rules and Web sites and other resources that are useful for developing an AML plan for a small firm.

 

Firms should also note that they may access all of the guidance FINRA has provided regarding FINRA Rule 3310 at the Anti-Money Laundering main page.

 

Changes to the AML Template Updated January 1, 2010

The updated template creates no new requirements. It replaces outdated NASD Rule 3011 references with new FINRA Rule 3310 cites. Also, it does not include the independent testing exception that was in the previous template; FinCEN stated the exception does not meet the Bank Secrecy Act’s independent testing requirements. The new template structure tracks previous templates, and generally matches up with AML plans based on those templates.

 

The more important changes in the new template are that it:

• notes that a firm’s AML program should be risk-based;
• notes that firms must identify, review, and if necessary, update the information regarding the AML compliance person in the manner prescribed in NASD Rule 1160;
• updates rule cites and resources, with hyperlinks directly to the cited material;
• reflects Treasury regulations issued since the template was last updated;
• adds a section on General Customer Due Diligence; and
• expands the red flag section to include insurance product and penny stock company transactions.