Firms must comply with the Bank Secrecy Act and its implementing regulations ("Anti-Money Laundering rules"). The purpose of the AML rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation.
FINRA reviews a firm’s compliance with AML rules under FINRA Rule 3310, which sets forth minimum standards for a firm’s written AML compliance program. The basic tenets of an AML compliance program under FINRA 3310 include the following.
- The program has to be approved in writing by a senior manager.
- It must be reasonably designed to ensure the firm detects and reports suspicious activity.
- It must be reasonably designed to achieve compliance with the AML Rules, including, among others, having a risk-based customer identification program (CIP) that enables the firm to form a reasonable belief that it knows the true identify of its customers.
- It must be independently tested to ensure proper implementation of the program.
- Each FINRA member firm must submit contact information for its AML Compliance Officer through the FINRA Contact System (FCS).
- Ongoing training must be provided to appropriate personnel.
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Anti-Money Laundering Template for Small Firms
FINRA provides an Anti-Money Laundering Template to assist Small Firms in establishing the AML compliance program required by the Bank Secrecy Act, its implementing regulations, and FINRA Rule 3310. The template provides text examples, instructions, relevant rules and Web sites, and other resources.
Anti-Money Laundering Forms
- Suspicious Activity Report (SAR) (must be filed electronically through the BSA E-Filing System)
- Currency Transaction Report (CTR) (must be filed electronically through the BSA E-Filing System)
- Report of Foreign Bank and Financial Accounts (FBAR) (FinCEN 114) Line Item Electronic Filing Instructions (must be filed electronically through the BSA E-Filing System)
- Report of International Transportation of Currency or Monetary Instruments (CMIR)
- Blocked Properties Reporting Form (OFAC)
- Voluntary Form for Reporting Blocked Transactions (OFAC)
- Voluntary Form for Reporting Rejected Transactions (OFAC)
FINRA's Anti-Money Laundering (AML) e-learning courses cover concepts and strategies for detecting and preventing money-laundering activity. Each course presents unique scenarios that illustrate typical money-laundering situations.
Visit our e-learning courses page to learn more.