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FINRA Unscripted: Jason Foye Discusses the Latest AML Trends and Emerging Threats

June 1, 2022
Volume 22


Upcoming Deadlines and Effective Dates
  • FINRA Election
  • SEC Request for Comment

Education and Compliance Programs

The Consolidated Audit Trail (CAT) NMS Plan Participants have determined to delay the full Customer Account Information System (CAIS) compliance deadline from July 11, 2022, to a date currently projected to be in the fourth quarter of 2022. For additional information, see Full CAIS Production Certification and Compliance Deadlines Extended.

Register today for the next Small Firm Conference Call on Monday, June 6, at 4:30 p.m. ET. FINRA CEO Robert Cook and Vice President of Member Relations and Education Kayte Toczylowski will be joined by Associate General Counsel Jeanette Wingler, Director of Member Supervision Brooke Hickman and Senior Director of Investor Education Christine Kieffer to discuss senior and at-risk investors. Registration is open to all member firms.

The Rule 4111 Compliance Tool is now available in the FINRA Gateway. As explained in new Rule 4111 FAQ 8.1, this tool will provide, as they are issued, reports of: (1) the annual calculation of whether the member firm met the Preliminary Criteria for Identification, including its Preliminary Identification Metrics, as of the Evaluation Date for a given year; and (2) interim calculations as of an Evaluation Date for that given year.

Each year’s report of the annual calculation will be issued shortly after the Rule 4111 annual calculation is conducted for that year. Prior to each year’s report of the annual calculation, FINRA will issue reports of interim calculations for that given year. The reports of interim calculations will be generated for informational purposes only; whether a firm will meet the Preliminary Criteria for Identification in the annual calculation could change based on subsequent events.

The report of the annual calculation of whether the member firm met the Preliminary Criteria for Identification as of the June 1, 2022, Evaluation Date will be issued in July 2022. The report of interim calculation as of that Evaluation Date has been issued and is now available in the Rule 4111 Compliance Tool.

In the FINRA Account Management System located in the FINRA Gateway, Super Account Administrators (SAAs) can assign eligible users the “Firm View Rule 4111 Compliance Tool” entitlement. It is located under Registrations, in the CRD section. If a firm’s SAA does not grant this entitlement to any of its users, the firm will be unable to access the tool.

For questions regarding the launch of this resource or entitlement questions, please contact the FINRA Call Center at (301) 869-6699 or send an email to the Compliance Tools team. For more information about Rule 4111, see FINRA Regulatory Notice 21-34, Information Notice 2/1/2022, and the Protecting Investors From Misconduct Key Topic page.


In the latest FINRA Unscripted episode, The Board Jason Foye, Senior Director of the National Cause and Finance Crimes Detection Program’s Special Investigative Unit, discusses the latest AML trends and emerging threats, and how firms can ensure their AML program remains strong and effective. Listen to the podcast.

 Upcoming Deadlines and Effective Dates

FINRA Election

As announced in Election Notice 5/16/22, FINRA firms will elect one Large Firm Governor and one Small Firm Governor to the FINRA Board of Governors at FINRA’s annual meeting in August. The Election Notice also announced that a petition period is currently underway for individuals who meet the eligibility requirements described within the Notice to be included on the ballot. During the petition period, interested individuals may contact the executive representatives of member firms to solicit their endorsements to become additional candidates in the election, which starts in July. Please be aware that you may receive calls or emails from petitioners during this time. In addition, some emails will be sent through a new email distribution system rather than directly from petitioners’ personal email addresses.
Petitions for candidacy are due June 30, 2022.

SEC Request for Comment

The SEC requests comment on FINRA’s proposal to expand TRACE reporting requirements to trades in U.S. dollar-denominated foreign sovereign debt securities. Comments are due June 7, 2022. See the Federal Register notice.


 Education and Compliance Programs

Super Account Administrators (SAAs) are invited to attend FINRA’s June 2 webinar 2 – 2:30 p.m. ET to prepare for the 2022 Annual Entitlement Certification Process. This year, SAAs will use the new Account Management system in FINRA Gateway to complete the certification process. During this webinar, FINRA will demonstrate the process and answer questions from attendees. Register to attend.

Week I of the 2022 FINRA Institute at Georgetown CRCP® Program has reached capacity. Register to join the waitlist for Week I.

Week II is filling up fast. Reserve your spot now. View the detailed schedule for a look at what sessions are being held and the participating faculty. Register today to join us in Washington, DC, for Week II November 13 – 18.

Register for all of FINRA’s upcoming events:

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Regulatory Contacts
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